Support for the evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action : final evaluation report.
Date: 2024-09-26
Institutions: Directorate-General for Energy
Subjects: EU Member State, adaptation to climate change, energy cooperation, energy efficiency, regulation (EU), renewable energy, report, sustainable development

Final Evaluation Report 
Support for the Evaluation of Regulation (EU) 
2018/1999 on the Governance of the Energy Union 
and Climate Action 

Written by Sophie Upson, Federico 
Solfrini, Valentina Cilli, Silvia Brunello, 
Jakob Rustige, Sara d’Auria, Michele 
Tolu, Loic Laurent, David Alemna, Koen 
van Lieshout, Jean-Sebastien Broc, 
Giulia Pizzini, Julia Panny, Barbara 
Breitschopf, Jakob Wachsmuth, James 
Sammut, Katie King. 

September 2024 

 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Directorate-General for Energy 

Directorate A —Energy policy: Strategy and Coordination 

Unit A.1 — Strategy, Policy Coordination and Planning, Inter-institutional Relations 

E-mail:  ENER-A1-2022-379-GOVERNANCE-REGULATION@ec.europa.eu 

European Commission 

B-1049 Brussels  

 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the 
Energy Union and Climate Action 

Final Evaluation Report 
Support for the Evaluation of Regulation (EU) 
2018/1999 on the Governance of the Energy Union 
and Climate Action 

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Luxembourg: Publications Office of the European Union, 2024 

ISBN 978-92-68-20424-5 

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Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the 
Energy Union and Climate Action 

Table of Contents 

Abstract ............................................................................................................ i 
Abrégé .............................................................................................................. i 
Executive summary ............................................................................................ii 

Introduction ....................................................................................................ii 
Purpose and scope of the evaluation ..................................................................ii 
Methodological approach...................................................................................ii 
Findings of the evaluation per evaluation criteria .................................................ii 

Résumé ........................................................................................................... vii 

Introduction .................................................................................................. vii 
Objectif et champ d’évaluation ....................................................................... viii 
Approche méthodologique .............................................................................. viii 
Résultats par critère d’évaluation .................................................................... viii 

List of abbreviations and acronyms .................................................................... xvi 
Introduction ................................................................................................ 1 
1 

1.1 
1.2 

Background and context ......................................................................... 2 
Purpose and scope of the evaluation ........................................................ 5 

2  Methodological approach to the evaluation ...................................................... 5 
3  What was the expected outcome of the Governance Regulation? ........................ 5 

3.1 
3.2 

Intervention logic of the Governance Regulation ........................................ 5 
Baseline for the evaluation .....................................................................10 

4  How has the situation evolved over the evaluation period? ...............................18 

Policy developments ..............................................................................18 
4.1 
4.2  Other developments (including changing geopolitical priorities) ..................23 

5  Findings of the evaluation answering all the evaluation questions ......................27 

To what extent was the intervention successful and why? ..........................27 
5.1 
5.2  How did the intervention make a difference and to whom? ....................... 159 
Is the intervention still relevant? .......................................................... 177 
5.3 

6  Conclusions and lessons............................................................................. 185 

Effectiveness ...................................................................................... 185 
6.1 
6.2 
Efficiency ........................................................................................... 187 
6.3  Coherence ......................................................................................... 188 
EU added value .................................................................................. 188 
6.4 
6.5  Relevance .......................................................................................... 189 

Annex 1. Methodological approach and limitations .............................................. 190 
Annex 2. Short summary on the feedback to the call for evidence ........................ 201 
Annex 3. Detailed method on the efficiency analysis ........................................... 206 

A3.1 Sources ............................................................................................... 206 
A3.2 Focus of the analysis............................................................................. 206 
Overview of benefits and costs ...................................................................... 220 

Annex 4. Evaluation framework ........................................................................ 233 
Annex 5. Case studies ..................................................................................... 255 
Annex 6. Synopsis Report ................................................................................ 349 
Annex  7.  Classification  of  obligations  from  energy  and  climate  acquis  included  in  the 
Governance Regulation (baseline) ..................................................................... 366 

 
 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the 
Energy Union and Climate Action 

Abstract 

The  study,  initiated  in  June  2023,  evaluates  the  Regulation  on  the  Governance  of  the 
Energy Union and Climate Action. It assesses the Regulation's implementation since 2018, 
focusing  on  effectiveness,  efficiency,  relevance,  coherence,  and  EU  added  value.  The 
research,  led  by  ICF  and  partners,  employed  mixed  methods,  including  desk  research, 
stakeholder consultations, and case studies across seven Member States. 

Findings indicate that while the Regulation improved planning and reporting quality, it did 
not ensure timely submission of National Energy and Climate Plans (NECPs) and Long-term 
Strategies (LTSs). The quality of reported information has improved, but inconsistencies 
and gaps remain, particularly in the completeness of NECPs and LTSs. The Regulation has 
partially  streamlined  planning  and  reporting  processes  but  has  not  achieved  full 
harmonization with other EU and international obligations. 

The  Regulation's  direct  impact  on  stimulating  spending  and  investment  is  unclear,  and 
regional  cooperation  could  be  further  encouraged.  Multi-level  and  multi-stakeholder 
dialogues  have  not  always  been  effectively  established.  The  Regulation's  compliance 
mechanism,  largely  based  on  non-binding  recommendations,  has  not  always  sufficiently 
ensured implementation. 

Overall, the Regulation has added value by enhancing the consistency of national energy 
and  climate  policies  and  their  planning.  However,  it  faces  challenges  in  ensuring 
accountability,  addressing  socio-economic  issues,  and  aligning  with  recent  legislative 
developments and global crises. 

Abrégé 

L'étude,  débutée  en  juin  2023,  évalue  le  règlement  sur  la  gouvernance  de  l'union  de 
l'énergie et de l'action pour le climat. Elle évalue la mise en œuvre du règlement depuis 
2018, en se concentrant sur l'efficacité, l'efficience, la pertinence, la cohérence et la valeur 
ajoutée  par  l'UE.  La  recherche,  menée  par  ICF  et  ses  partenaires,  a  utilisé  une 
méthodologie mixte comprenant des recherches documentaires, des consultations avec les 
parties prenantes et des études de cas dans sept États membres. 

Les résultats indiquent que si le règlement a amélioré la qualité de la planification et des 
rapports  d’informations,  il  n'a  pas  garanti  la  présentation  en  temps  voulu  des  plans 
nationaux pour l'énergie et le climat (PNEC) et des stratégies à long terme (SLT). La qualité 
des  informations  communiquées  s'est  améliorée,  mais  des  incohérences  et  des  lacunes 
subsistent,  notamment  en  ce  qui  concerne  l'exhaustivité  des  PNEC  et  des  SLT.  Le 
règlement  a  partiellement  rationalisé  les  processus  de  planification  et  de  rapport 
d’informations,  mais  n'a  pas  permis  une  harmonisation  totale  avec  d'autres  obligations 
européennes et internationales. 

L'impact direct du règlement sur la stimulation des dépenses et des investissements n'est 
pas  clair  et  la  coopération  régionale  pourrait  être  davantage  encouragée.  Les  dialogues 
multi-niveaux  et  multi-parties  n'ont  pas  toujours  été  établis  de  manière  efficace.  Le 
mécanisme  de  conformité  du  règlement,  largement  basé  sur  des  recommandations  non 
contraignantes, n’a pas toujours garanti une mise en œuvre suffisante. 

Dans  l'ensemble,  le  règlement  a  apporté  une  valeur  ajoutée  en  renforçant  la  cohérence 
des  politiques  nationales  en  matière  d'énergie  et  de  climat,  ainsi  que  leur  planification. 
Toutefois, il doit relever des défis en matière de responsabilité, de traitement des questions 
socio-économiques  et  d'alignement  sur  les  évolutions  législatives  récentes  et  les  crises 
mondiales. 

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Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the 
Energy Union and Climate Action 

Executive summary 

Introduction 

This study was launched by the European Commission Directorates-General for Energy (DG 
ENER) and Climate Action (DG CLIMA) in June 2023 to support the European Commission’s 
evaluation  of  Regulation  (EU)  2018/1999  on  the  Governance  of  the  Energy  Union  and 
Climate  Action  (Governance  Regulation  or  Regulation).  This  Final  Evaluation  Report 
presents the results of  the research, including the answers to  each evaluation question, 
informed by mixed-methods research conducted between June 2023 and February 2024. 
The  research  was  led  by  researchers  from  ICF  and  project  partners  Fraunhofer,  Aether, 
Institute for European Energy and Climate Policy (IEECP) and Cambridge Econometrics.  

Purpose and scope of the evaluation  

The  objective  of  this  study  is  to  support  the  European  Commission  in  conducting  an 
evaluation of the Governance Regulation with a view to aiding its preparation of a report 
to the European Parliament and the Council in line with Article 45 of the Regulation. The 
study assessed how the Regulation has been implemented since 2018 (ex-post evaluation) 
based  on  the  five  core  Better  Regulation  criteria:  effectiveness,  efficiency,  relevance, 
coherence, and European Union (EU) added value.   

Methodological approach 

The  study  draws  on  desk  research,  a  mapping  of  legal  obligations  pertaining  to  the 
Regulation, and a multidimensional stakeholder consultation comprising a Call for Evidence 
(CfE),  telephone  interviews  with  key  stakeholders,  targeted  online  surveys  (covering 
Member  States  authorities,  industry,  and  third  sector  stakeholders),  and  a  stakeholder 
event organised by the European Commission in Brussels.  

The  CfE  was  conducted  by  the  European  Commission  during  July  and  August  2023  and 
received  54  replies,  from  non-governmental  organisations  (NGOs)  (18),  environmental 
organisations  (4),  EU  citizens  (9),  business  associations  (7),  companies/businesses  (5), 
public  authorities  (6),  academia/research  institutions  (3)  and  others  (2).  The  targeted 
surveys  were  conducted  by  ICF  and  received  70  replies,  from  national  authorities  (33), 
third-sector stakeholders (20), and industry organisations (17). Forty-four semi-structured 
interviews (including 10 scoping interviews) were carried out with key stakeholders as part 
of the main interview programme, with a further 36 interviews serving as input to the case 
studies.  The  case  studies  explore  the  Governance  Regulation  in  greater  depth  in  seven 
Member  States  (Belgium,  Denmark,  France,  Germany,  Malta,  Romania,  and  Poland), 
particularly its costs and benefits. The study also draws from the findings of a stakeholder 
event organised by DG ENER and DG CLIMA in January 2024, involving approximately 120 
representatives from Member States’ national authorities, industry organisations and civil 
society organisations.  

The information from these various strands of research was collated, synthesised, analysed 
and  triangulated  to  draw  robust  conclusions  to  the  evaluation  questions.  Much 
consideration  was  given  to  the  pre-existing  situation  in  the  Member  States  before  the 
Regulation entered into force in 2018. Evidence was  collected to  establish the  extent to 
which the Regulation can be considered more effective, relevant, coherent, and/or efficient 
against this baseline, and the extent to which it provides EU added value.   

Findings of the evaluation per evaluation criteria 

Effectiveness 

Although the Regulation improved planning across the Energy Union’s five dimensions and 
enhanced the quality of reported information, it did not ensure the timely submission of 
national  energy  and  climate  plans  (NECPs)  (chapter  2  of  the  Regulation)  and  long-term 
strategies (LTSs) (chapter 3). Member States also took different approaches to reporting 

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Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the 
Energy Union and Climate Action 

information in accordance  with their  reporting  obligations (chapter 4 of the Regulation). 
Additionally, some NECPs were insufficiently detailed.  

Quality of information reported 

Compared  to  the  baseline,  the  Governance  Regulation  contributed  to  improving  the 
transparency, quality, and effectiveness of the reporting requirements. Most stakeholders 
surveyed  (55 %)  indicated  that  the  Governance  Regulation  has  contributed  to  more 
complete,  reliable,  and  accessible  data,  at  least  partially.  However,  the  effects  of  the 
Regulation  have  been  less  noticeable  in  Member  States  with  (reportedly)  strong  pre-
existing frameworks for the EU reporting of climate policy.  

The Governance Regulation lays down the rules on the NECPs, including their procedural 
aspects (process) involving the EU Member States and the EU Commission. Although the 
Regulation enhanced the quality of planning, some gaps and issues of NECP completeness 
remain,  as  confirmed  by  the  2023  EU-wide  assessment  of  the  draft  updated  NECPs. 
Individual Member States have taken different approaches to reporting information in their 
NECPs, impacting the consistency of the information. Some NECPs also omit  mandatory 
content.  

The entry into force of the Governance Regulation marked a significant evolution from the 
framework  established  by  Regulation  (EU)  No  525/2013  (Monitoring  Mechanism 
Regulation,  MMR).  Previously,  strategies  for  energy,  climate  mitigation  and  climate 
adaptation were fragmented. The Regulation sets out the obligations and processes for the 
Member States and the European Commission to prepare and submit their national long-
term  strategies.  While  the  Regulation  has  helped  to  ensure  that  LTSs  reflect  the  five 
dimensions  of  the  Energy  Union,  divergent  national  planning  traditions  have  negatively 
impacted  their  completeness.  Overall,  a  lack  of  sufficient  quantitative  data  and  sector-
specific information was noted.  

The Governance Regulation requires Member States to produce biennial progress reports 
on  the  implementation  of  their  NECPs  (from  15  March  2023  onwards)  to  track  progress 
across  the  five  dimensions  of  the  Energy  Union.  Enforcement  has  only  been  partially 
effective however, leaving significant data gaps.  

EU  Member  States  are  required  to  report  their  national  policies  and  measures  (PaMs) 
related to GHG emissions reduction. This reporting can then serve as a repository for PaMs. 
Further  improvements  are  needed,  however.  In  2023,  Member  States  reported  a 
substantial  increase  in  single  PaMs  compared  to  the  previous  year,  reflecting  the 
implementation  of  NECPs.  However,  the  provision  of  quantitative  information  remains 
challenging:  indicators  for  PaMs  were  reported  by  17  Member  States,  but  often  lacked 
quantitative data. While qualitative data improved, indicators, costs, benefits, and emission 
savings were underreported. Overall, enhancing completeness and transparency is crucial 
for effective climate policy evaluation and planning. 

The completeness of mandatory reporting on projections of anthropogenic GHG emissions 
by  sources  and  removals  by  sinks  under  Article  18(1)(b)  of  the  Regulation  did  not 
significantly changed for most Member States between 2019 – prior to the entry into force 
of the Regulation – and 2021, based on available data from the European Environmental 
Agency (EEA). All Member States submitted the mandatory ‘with existing measures’ (WEM) 
scenario and related parameters. However, in 2021, eight Member States did not provide 
information  on  the  sensitivity  analysis  for  their  projections.  Member  States’  have  only 
recently  developed  (or  are  in  the  process  of  developing)  monitoring  and  evaluation 
frameworks for adaptation reporting. These frameworks operate within national adaptation 
strategies or plans but rarely consider synergies with Energy Union dimensions. Only 13 
Member States have reported clear progress in implementing actions for each adaptation 
goal, according to the State of the Energy Union 2023 Report. 

In  2023,  Member  States  provided  only  limited  information  on  integrated  reporting  on 
renewable energy (Article 20 of the Regulation), and the information that was provided is 
not easily comparable. 

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Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the 
Energy Union and Climate Action 

The  2023  NECPs  also  fail  to  provide  information  on  energy  efficiency,  particularly  the 
exemplary  role  of  public  bodies'  buildings  (Article  5  of  Directive  2012/27/EU  (Energy 
Efficiency Directive, EED). By contrast, under the Energy Audit Obligation (Article 8 of the 
EED), only two Member States did not report information on the number of large companies 
for  2021.  Some  energy  audit  information  for  2020  was  missing,  with  only  13  Member 
States reporting both the number of large companies and the energy audits carried out. 

On  integrated  reporting  on  research,  innovation  and  competitiveness  (Article  25  of  the 
Regulation),  three  Member  States  did  not  report  information  on  the  financing  of  PaMs, 
while  those  that  did  report  often  provided  incomplete  or  inconsistent  data.  This  lack  of 
proper  reporting  on  investment  needs  and  funding  sources  fails  to  accurately  identify 
funding needs and gaps, which is central to sound strategic planning and implementation. 
It also makes it impossible to assess the effectiveness of public support and its impact on 
public finances. 

On the annual reporting on the 2020 targets, gaps remain in the information provided in 
2020  target  reports,  including  missing  data  from  past  annual  reports.  Member  States’ 
different reporting approaches make it challenging to assess overall target achievement. 
Some Member States introduced new measures in their 2020 target reports to accelerate 
progress.  

Timeliness of information  

The  Governance  Regulation  has  not  guaranteed  the  timely  submission  of  draft  National 
Energy  and  Climate  Progress  Reports  (NECPRs).  However,  it  is  unclear  whether  delays 
were caused by the Governance Regulation or by practices and/or procedural bottlenecks 
at Member State level.  

There  were  also  significant  delays  in  the  submission  of  LTSs,  in  turn  causing  lags  and 
inefficiencies  in  the  Commission’s  EU-wide  assessment  of  the  LTSs.  Delays  to  the 
submission  of  LTSs  seem  to  reflect,  at  least  partly,  a  lack  of  administrative  capacity  at 
national level.  

Biennial progress reports and their follow up (NECPRs and reporting obligations stemming 
from  Article  17  of  the  Governance  Regulation)  were  submitted  either  on  time  or  with  a 
small delay, which did not impact the effectiveness of the Governance Regulation.  

Prior to 2021, PaMs were not yet reported on the basis of the Regulation. However, the 
timeliness of information on PaMs remained stable between 2017 and 2019, improved in 
2021, then decreased in 2023. Information reported on projections of anthropogenic GHG 
emissions  by  sources  and  removals  by  sinks  improved  in  2019  compared  to  2017,  but 
deteriorated in 2021.  

(Public) accessibility of information  

The Governance Regulation has increased (public) accessibility of information somewhat. 
Stakeholders have highlighted limitations to public accessibility of information, especially 
as  the  information  is  complex  and  not  in  an  easy-to-use  format.  However,  it  remains 
unclear whether these issues are linked to the Governance Regulation or, more likely, to 
implementation issues and/or national traditions across the EU.  

Planning processes and implementation of plans  

The Governance Regulation has been effective in promoting better planning processes. It 
helped  to  streamline  planning  processes  across  the  energy  and  climate  domains,  with 
increased  cooperation  among  different  ministries/authorities  at  national  level.  While  the 
Governance  Regulation  enhanced  planning,  NECPs  are  not  always  aligned  with  national 
planning processes and, in such cases, are mainly developed to meet the EU obligation.  

In  a  number  of  cases,  national  planning  traditions  may  have  negatively  impacted  the 
completeness of LTSs, with Member States not reporting all mandatory content or failing 
to do so coherently with their NECPs. Similarly, LTSs are partly outdated (no mandatory 
need to update them) and do not necessarily serve as the basis for NECP development.  

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Energy Union and Climate Action 

Stakeholders  underlined  the  lack  of  attention  paid  to  LTSs,  including  the  lack  of  a  close 
monitoring process of LTSs after their adoption.  

The national authorities consulted agreed that the Governance Regulation contributed to 
the adoption  or implementation of PaMs to meet national energy and  climate  objectives 
and targets. However, some factors negatively affected both the planning processes and 
the  effective  implementation  of  plans  and  reports  (e.g.  lack  of  provisions  within  the 
Governance Regulation to ensure coherence between NECPs and LTSs).  

Compliance   

The Governance Regulation has been only partially effective in responding to ambition or 
implementation deficits. One of the main factors underpinning implementation deficits is 
that  the  Regulation’s  compliance  mechanism  is  based  primarily  on  recommendations, 
which have no binding force.  

Stimulating spending and investment  

Consultations provided limited feedback on the Regulation’s impact on stimulating targeted 
spending  and  investments  and  on  creating  increased  predictability  for  investors. 
Nevertheless, stakeholders recognised that the Regulation provides a stable framework for 
clean  energy  businesses,  which  some  indicated  is  crucial  for  long-term  investment  and 
development in the sector.  

The Commission’s assessments show that NECPs lacked detail on investment needs and 
funding sources – this was confirmed by industry stakeholders.  

Stakeholders were not always aware of the situation before the Governance Regulation or 
were  unable  to  link  or  attribute  specific  trends  in  spending  and  investment  to  the 
Regulation.  

Ensuring regional cooperation  

Both the 2019 EU-wide assessment of draft NECPs and the 2020 EU-wide assessment of 
final  NECPs  indicated  the  need  to  enhance  regional  cooperation  efforts.  The  2020 
assessment  found  that  while  Member  States  understood  and  described  the  need  for 
regional cooperation, with some making use of existing regional forums, the full potential 
of  regional  cooperation  was  untapped.  The  2023  Commission’s  assessment  of  progress 
towards the objectives of the Energy Union and Climate Action revealed that most Member 
States reported progress in implementing regional cooperation, with advances in at least 
one  of  their  regional  cooperation  initiatives  or  projects.  However,  the  2023  EU-wide 
assessment of the draft NECPs confirmed that regional cooperation is evident to a limited 
extent  across  the  Member  States  and  is  confined  to  specific  areas  (e.g.  bilateral 
agreements on the security of gas supply).  

Ensuring adequate multi-level and multi-stakeholder dialogue and consultation 

The  evidence  found  that  while  Articles  10  and  11  of  the  Governance  Regulation  are 
perceived as a step forward, the Regulation has not been particularly successful in ensuring 
adequate  multi-level  and  multi-stakeholder  dialogue  and  consultation.  Several  Member 
States failed to establish mechanisms of sufficient quality.      

Efficiency 

The  efficiency  analysis  showed  mixed  results.  The  Regulation  has  streamlined  some 
aspects of energy policy planning and reporting, leading some Member States to realise 
savings  in  time  and/or  resources.  However,  several  Member  States  experienced  an 
increased administrative burden. It is difficult to disentangle the workload created by the 
Regulation  from  that  generated  by  organisational  aspects  of  national  administrations 
(including limited coordination between those involved in reporting obligations at a national 
level),  the  evolution  of  national/EU  legislative  frameworks,  and  reporting  obligations 
already in place.  

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Energy Union and Climate Action 

Recognised  improvements  introduced  by  the  Governance  Regulation  include  higher 
coherence of planning and reporting timelines and procedures, increased transparency and 
predictability,  better  cross-border  coordination,  enhanced  cooperation  between  national 
authorities,  and  better-established  processes,  policies,  and  procedures.  Although  the 
benefits  have  not  yet  fully  materialised,  many  stakeholders  (especially  within  national 
authorities)  reported  that  the  Regulation  is  pushing  national  administrations  to  work 
together more closely and establish new coordination procedures. 

Stakeholders  (especially  national  authorities)  also  acknowledged  an  ongoing  learning 
curve: while the initial reporting cycles were relatively complex, the process is expected to 
become easier and less burdensome over time.  

While  the  Regulation  has  partially  streamlined  planning,  reporting  and  monitoring 
processes, it has not achieved complete harmonisation and full alignment with the timing 
of other EU and international obligations, as indicated by the mixed stakeholder feedback 
and  survey  responses.  Stakeholders  noted  that  the  five-year  timeframe  for  strategic 
decisions in the energy sector is insufficient, as significant shifts in energy systems typically 
require longer-term planning. The timetables for some obligations (e.g. preparing NECPs 
and  NECPRs  in  close  succession)  makes  it  more  difficult  to  draw  lessons  from  previous 
planning  cycles.  Some  annual  reporting  obligations  (especially  those  under  Article  26  of 
the Regulation) strain the resources of both Member States and EU institutions. The biggest 
challenge in respect of international obligations is that both the United Nation Framework 
Convention  on  Climate  Change  (UNFCCC)  and  the  EU  frameworks  on  GHG  emissions 
include  biennial  reporting  obligations,  but  in  different  years  (even  years  for  UNFCCC/ 
Biennial Transparency Report (BTR) and odd years for NECPRs). 

The  Regulation  introduced  common  templates  for  NECPs  and  NECPRs,  as  well  as 
introducing  (ReportENER)  or  strengthening  (Reportnet)  digital  platforms.  Stakeholders 
expressed mixed views about the time and/or resource savings of these common templates 
and platforms. On the one hand, stakeholders referred to the cost of reformulating data 
and information before uploading it and emphasised the lack of a tool for compiling and 
sharing comprehensive answers from different authorities within each reporting country. 
They  also  noted  inadequate  connections  and  differences  in  formats  between  the  two 
platforms. On the  other hand, some cost/burden reductions have been achieved, as the 
platforms provide additional clarity about the information and data that should be collected 
and submitted. They also remove the need for Member States to develop their own national 
tools and enable several users to access information simultaneously. Some stakeholders 
noted that the two platforms play a role in standardising reporting and systematising data 
collection, as well as facilitating availability and comparability of information.  

Coherence 

The Regulation has improved the coherence of planning and reporting obligations that were 
previously scattered across energy, climate, and other Energy Union-related legislation and 
policy  areas.  However,  persistent  inconsistencies  affect  both  the  internal  and  external 
coherence of the Regulation. 

Issues  with  internal  coherence  mostly  stem  from  the  complexity  of  integrating  many 
obligations into a single legal framework and the related legal changes that have occurred 
since the Regulation was adopted in 2018.  

External  coherence  issues  largely  relate  to  the  EU-level  instruments  introduced  and/or 
updated after 2018, notably the various policies developed under the European Green Deal. 
For instance, the recast EED includes many new elements for a stronger governance that 
are not currently incorporated nor streamlined into the Regulation, Similarly, the revised 
Directive  (EU)  2018/2001  (Renewable  Energy  Directive,  RED)  introduced  new  elements 
that are not reflected in the Regulation. In addition, there is scope for further alignment 
with other planning/reporting obligations, such as the UNFCCC reporting cycle.  

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Relevance 

The  Governance  Regulation's  core  objective  of  providing  a  governance  structure  that 
enables and pushes Member States to commit and deliver on ambitious energy and climate 
targets remains relevant. Indeed, it has become more relevant, given the growing need 
for  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  Governance 
Regulation – to enable and support climate action and the Energy Union – is more relevant 
than ever.  

Since the Governance Regulation was adopted in 2018, the EU energy and climate acquis 
has undergone important developments, notably the 'Fit for 55' package. As  a primarily 
procedural framework that does not itself set specific targets, this has not rendered the 
Governance  Regulation  obsolete.  However,  certain  issues  reflected  in  recent  legislation 
need  to  be  better  addressed  in  the  outputs  delivered  under  the  Regulation,  including 
NECPs. 

The Regulation does not adequately address some of the issues that have become more 
prominent following Russia’s war of aggression against Ukraine, such as energy security 
and the need for a competitive clean energy industry.  The energy supply crisis and the 
COVID-19 pandemic highlighted social and economic challenges that need to be addressed 
if climate change and just transition goals are to be met in the long term. Feedback from 
stakeholders  suggests  that  socioeconomic  issues,  such  as  energy  poverty  and  labour 
shortages,  are  not  adequately  addressed  by  the  Regulation.  That  inadequacy  is 
exacerbated by the lack of robust macroeconomic assessments of the measures included 
in NECPs.  

EU added value 

The Regulation has enhanced the consistency of national energy and climate policies and 
planning,  although  the  impact  varies  across  Member  States,  in  part  due  to  pre-existing 
national processes. Stakeholders stressed that coordination with sub-national actors could 
be strengthened. 

The  Regulation’s  planning  and  reporting  obligations  have  given  rise  to  additional 
information at EU and national level. By requiring Member States to publish reports and 
data they did not previously collect or report, the Regulation has increased the availability 
of  information  and  enabled  stakeholders,  including  Member  State  authorities  and  the 
European Commission, to access other Member States’ plans and assessments. Crucially, 
it 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.  Nevertheless, 
issues  with  timely  submission,  quality  (completeness), 
stakeholders  highlighted 
accessibility and transparency of data.  

There  were  contrasting  views  on  the  added  value  of  the  Regulation  in  ensuring 
accountability and access to justice, with some stakeholders (mainly national authorities) 
highlighting positive effects and others (mainly third sector stakeholders) highlighting the 
significant improvements still needed.  

Résumé 

Introduction 

Cette étude a été commandée par la DG ENER et la DG CLIMA en juin 2023 pour informer 
l'évaluation  par  la  Commission  européenne  du  règlement  (UE)  2018/1999  sur  la 
gouvernance de l'Union de l'énergie et de l'action pour le climat (en abrégé, le « règlement 
sur la gouvernance » ou « règlement »). Ce rapport d'évaluation final présente les résultats 
de la recherche et inclut les réponses à chacune des questions d'évaluation. Le rapport a 
été alimenté par une recherche suivant une méthodologie mixte, conduite entre juin 2023 

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et février 2024. Cette recherche a été menée par des chercheurs d'ICF et ses partenaires 
sur le projet: Fraunhofer, Aether, IEECP et Cambridge Econometrics.  

Objectif et champ d’évaluation   

L'objectif de cette étude était de soutenir la Commission européenne dans la conduite d'une 
évaluation du règlement sur la gouvernance en vue de l'aider à préparer son rapport au 
Parlement  européen  et  au  Conseil  conformément  à  l'article  45  du  règlement.  L'étude  a 
évalué  la  manière  dont  le  règlement  a  été  mis  en  œuvre  depuis  2018  (c'est-à-dire  une 
évaluation  ex  post)  sur  la  base  des  cinq  critères  fondamentaux  du  programme 
d’amélioration  de  la  réglementation,  à  savoir  l'efficacité,  l'efficience,  la  pertinence,  la 
cohérence et la valeur ajoutée de l'UE.   

Approche méthodologique 

L'étude s'appuie sur des recherches documentaires, un inventaire des obligations légales 
relatives  au  règlement  et  une  consultation  multidimensionnelle  des  parties  prenantes 
comprenant  un  appel  à  contribution,  des  entretiens  téléphoniques  avec  les  principales 
parties  prenantes,  des  enquêtes  en  ligne  ciblées  (couvrant  les  autorités  des  États 
membres,  les  acteurs  économiques  et  les  parties  prenantes  du  troisième  secteur),  ainsi 
qu'un atelier organisé à Bruxelles par la Commission européenne à l'intention des parties 
prenantes.   

L'appel à contribution a été mené par la Commission européenne en juillet et août 2023 et 
a reçu 54 réponses d'ONG (18), d'organisations environnementales (4), de citoyens de l'UE 
(9), d'associations d’entreprises (7), de sociétés/entreprises (5), d'autorités publiques (6), 
d'universités/institutions de recherche (3) et d'autres acteurs (2). Les enquêtes ciblées ont 
été  menées  par  ICF  et  ont  reçu  70  réponses  d'autorités  nationales  (33),  de  parties 
prenantes  du  troisième  secteur  (20)  et  d'organisations  des  secteurs  économiques  (17). 
Quarante-quatre  (44)  entretiens  semi-structurés  (dont  10  entretiens  de  cadrage)  ont 
également été menés avec les principales parties prenantes dans le cadre du programme 
d'entretiens principal, et 36 autres entretiens ont été menés pour alimenter les études de 
cas.  Les  études  de  cas  explorent  plus  en  détail  la  situation  dans  sept  États  membres 
(Belgique, Danemark, France, Allemagne, Malte, Roumanie et Pologne) et se concentrent 
particulièrement  sur  les  coûts  et  les  avantages  liés  au  règlement  sur  la  gouvernance. 
L'étude s'appuie également sur les conclusions d'une discussion organisée par les DG ENER 
et CLIMA en janvier 2024, à laquelle ont participé environ 120 représentants des autorités 
nationales  des  États  membres,  d'organisations  des  secteurs  économiques  et 
d'organisations de la société civile.  

Les  informations  issues  de  ces  différents  axes  de  recherche  ont  été  rassemblées, 
synthétisées, analysées et confrontées afin de tirer des conclusions solides aux questions 
d'évaluation.  Au  cours  de  ce  processus,  une  attention  particulière  a  été  accordée  à  la 
situation  de  base,  c'est-à-dire  à  la  situation  préexistante  dans  les  États  membres  avant 
l'entrée en vigueur du règlement en 2018. Sur cette base, des éléments probants ont été 
recueillis  pour  déterminer  dans  quelle  mesure  le  règlement  peut  être  considéré  comme 
plus  efficace,  plus  pertinent,  plus  cohérent  et/ou  plus  efficient  et  dans  quelle  mesure  il 
apporte une valeur ajoutée.  

Résultats par critère d’évaluation 

Efficacité 

Bien que le règlement ait amélioré la planification à travers les cinq dimensions de l'Union 
de  l'énergie,  ainsi  que  la  qualité  des  informations  communiquées,  il  n'a  pas  garanti  la 
présentation en temps utile des plans nationaux en matière d'énergie et de climat (PNEC) 
(chapitre  2  du  règlement)  et  des  stratégies  à  long  terme  (SLT)  (chapitre  3).  Les  États 
membres  ont  également  adopté  des  approches  différentes  afin  de  répondre  à  leurs 

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obligations  de  rapport  d’informations  prévues  au  chapitre  4  du  règlement.  En  outre, 
certains PNEC se sont avérés être insuffisamment détaillés.  

Qualité des informations communiquées 

Dans  l'ensemble,  par  rapport  à  la  situation  de  base,  le  règlement  sur  la  gouvernance  a 
contribué à améliorer la transparence, la qualité et l'efficacité des exigences en matière de 
rapport d’informations sur plusieurs aspects qui n'étaient pas efficaces auparavant ou qui 
étaient excessivement dispersés dans des obligations hétérogènes. À cet égard, la plupart 
des parties prenantes interrogées (55 %) ont indiqué que le règlement sur la gouvernance 
avait contribué à rendre les données communiquées plus complètes, plus fiables et plus 
accessibles, du moins en partie. Néanmoins, dans les États membres disposant (semble-
t-il)  de  cadres  préexistants  solides  pour  l'établissement  de  rapports  sur  les  politiques 
climatiques  de  l'UE,  déjà  en  place  avant  l'entrée  en  vigueur  du  règlement  sur  la 
gouvernance, les effets du règlement ont été moins perceptibles. 

Le règlement sur la gouvernance définit les règles relatives aux plans nationaux intégrés 
en matière d'énergie et de climat (PNEC), y compris leurs aspects formels (de procédure) 
impliquant les États membres de l'UE et la Commission européenne. Bien que le règlement 
ait amélioré la qualité de la planification, il subsiste des lacunes et des problèmes liés à 
l'exhaustivité  des  PNEC,  comme  l'a  confirmé  en  2023  l'évaluation  à  travers  les  États 
membres  des  projets  de  PNEC  mis  à  jour.  En  outre,  les  États  membres  ont  adopté  des 
approches  différentes  en  matière  de  rapport  d'informations  dans  leurs  PNEC,  avec  pour 
conséquence une incohérence des informations contenues dans les PNEC. Certains PNEC 
omettent également des informations obligatoires.   

L'entrée  en  vigueur  du  règlement  sur  la  gouvernance  (règlement  (UE)  2018/1999)  a 
marqué  une  évolution  significative  par  rapport  au  cadre  établi  via  le  mécanisme  de 
surveillance et de déclaration (règlement (UE) n° 525/2013). Avant l'entrée en vigueur du 
règlement  sur  la  gouvernance,  les  stratégies  en  matière  d'énergie,  d'atténuation  du 
changement climatique et d'adaptation au changement climatique étaient fragmentées. Le 
règlement définit les obligations et les processus permettant aux États membres et à la 
Commission européenne de préparer et de soumettre leurs stratégies à long terme. Si le 
règlement a contribué à faire en sorte que les stratégies de développement à long terme 
tiennent  compte  des  cinq  dimensions  de  l'union  de  l'énergie,  des  traditions  nationales 
divergentes en matière de planification ont eu une incidence négative sur leur exhaustivité. 
Dans  l'ensemble,  le  manque  de  données  quantitatives  suffisantes  et  d'informations 
spécifiques aux secteurs a également été constaté.  

En outre, le règlement sur la gouvernance exige des États membres qu'ils produisent des 
rapports d'avancement biannuels sur la mise en œuvre de leurs PNEC, à partir du 15 mars 
2023, afin de suivre les progrès réalisés dans les cinq dimensions de l'union de l'énergie. 
En ce qui concerne les rapports d'avancement bisannuels et leur suivi, la mise en œuvre 
n'a été que partiellement efficace, laissant subsister d'importantes lacunes en matière de 
données disponibles.  

Les  États  membres  de  l'UE  sont  tenus  de  rendre  compte  de  leurs  politiques  et  mesures 
nationales en matière de réduction des émissions de gaz à effet de serre (GES). Le potentiel 
de  ce  rapport  réside  dans  le  fait  qu'il  sert  de  référentiel  pour  les  politiques  et  mesures 
nationales, mais d'autres améliorations sont nécessaires. En 2023, les États membres ont 
déclaré une augmentation substantielle des politiques et mesures nationales, reflétant la 
mise  en  œuvre  des  PNEC,  par  rapport  à  l'année  précédente.  Toutefois,  la  fourniture 
d'informations quantitatives reste difficile. Si les données qualitatives se sont améliorées, 
les  indicateurs,  les  coûts,  les  avantages  et  les  réductions  d'émissions  n'ont  pas  été 
suffisamment communiqués. Les indicateurs relatifs aux politiques et mesures nationales 
ont  été  communiqués  par  17  États  membres,  mais  les  données  quantitatives  faisaient 

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souvent  défaut.  Dans  l'ensemble,  il  est  essentiel  d'améliorer  l'exhaustivité  et  la 
transparence pour une évaluation et une planification efficaces de la politique climatique. 

L'exhaustivité  des  déclarations  obligatoires  en  matière  de  projections  relatives  aux 
émissions  anthropiques  de  gaz  à  effet  de  serre  par  les  sources  et  à  l'absorption  par  les 
puits de gaz à effets de serre, au titre de l'article 18, paragraphe 1, point b), n'a pas changé 
de manière significative pour la plupart des États membres entre 2019 – avant l'entrée en 
vigueur du règlement – et 2021, sur la base des données disponibles auprès de l'Agence 
européenne pour l'environnement (AEE). Toutefois, en 2021, huit États membres n'ont pas 
fourni d'informations sur l'analyse de sensibilité de leurs projections. En ce qui concerne 
les rapports sur l'adaptation, les cadres de suivi et d'évaluation des États membres n'ont 
été élaborés que récemment ou sont encore en cours d'élaboration. Ces cadres s'inscrivent 
dans les stratégies ou plans nationaux d'adaptation, mais prennent rarement en compte 
les  synergies  entre  les  dimensions  de  l'union  de  l'énergie.  Selon  le  rapport  de  2023  sur 
l'état de l'union de l'énergie, seuls treize États membres ont fait état de progrès clairs dans 
la mise en œuvre de mesures d'adaptation pour chaque objectif d'adaptation. 

En  ce  qui  concerne  les  rapports  intégrés  sur  les  énergies  renouvelables  (article  20),  les 
États membres n'ont fourni qu'un nombre limité d'informations en 2023, et celles qui ont 
été fournies ne sont pas facilement comparables. 

Les rapports nationaux d’avancement énergie-climat de 2023 ne fournissent pas non plus 
d'informations  sur  l'efficacité  énergétique,  notamment  en  ce  qui  concerne  le  rôle 
exemplaire des bâtiments des organismes publics (article 5 de la directive sur l'efficacité 
énergétique  (DEE)).  En  revanche,  en  ce  qui  concerne  l'obligation  d'audit  énergétique 
(article 8 de la DEE), seuls deux États membres n'ont pas communiqué d'informations sur 
le nombre de grandes entreprises pour 2021. En ce qui concerne les audits énergétiques, 
certaines informations manquaient pour 2020, étant donné que seuls 13 États membres 
avaient communiqué à la fois le nombre de grandes entreprises et les audits énergétiques 
réalisés. 

Pour ce qui est du rapport intégré sur la recherche, l'innovation et la compétitivité (article 
25), trois États membres n'ont pas communiqué d'informations sur le financement de leurs 
politiques  et  mesures  nationales,  tandis  que  les  informations  fournies  par  les  États 
membres  qui  ont  communiqué  des  données  sont  souvent  incomplètes  ou  incohérentes. 
Cette absence d’informations appropriées sur les besoins d'investissement et les sources 
de  financement  est  problématique  car  elle  ne  permet  pas  d'identifier  avec  précision  les 
besoins et les lacunes en matière de financement, ce qui est essentiel pour une planification 
et  une  mise  en  œuvre  stratégiques  robustes.  Il  est  également  impossible  d'évaluer 
l'efficacité de l'aide publique et son impact sur les finances publiques. 

En ce qui concerne les rapports annuels sur les objectifs spécifique de 2020 (article 27), 
des lacunes subsistent dans les informations fournies, y compris des données manquantes 
dans les rapports annuels précédents. Les différences d'approche entre les États membres 
en matière d'établissement de leurs rapports rendent difficile l'évaluation de la réalisation 
globale  des  objectifs.  Certains  États  membres  ont  introduit  de  nouvelles  mesures  dans 
leurs rapports sur les objectifs spécifiques de 2020 afin d'accélérer leurs progrès. 

Mise à disposition des informations en temps voulu 

Le règlement sur la gouvernance n'a pas garanti la présentation en temps utile des projets 
de PNEC. Cependant, il n'est pas clair si les retards ont été causés par le règlement ou par 
des pratiques et/ou des points de blocages procéduraux dans les États membres.  

Des retards importants ont également été enregistrés dans la présentation des SLT, ce qui 
a entraîné des retards et un manque d'efficacité dans le processus d'évaluation des SLT 
par la Commission à l'échelle de l'UE. Les retards dans la présentation des SLT semblent 

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avoir  été  causés,  au  moins  en  partie,  par  un  manque  de  ressources  administratives  au 
niveau national.  

Les rapports d'avancement biannuels et leur suivi (obligations découlant de l'article 17 du 
règlement)  ont  été  soumis  soit  à  temps,  soit  avec  un  léger  retard,  ce  qui  n'a  pas  eu 
d'incidence sur l'efficacité du règlement sur la gouvernance.  

Avant  2021,  les  politiques  et  mesures  nationales  n'étaient  pas  déclarés  sur  la  base  du 
règlement  sur la gouvernance. Néanmoins, le  respect des délais dans la communication 
des informations relatives aux politiques et mesures nationales est resté stable entre 2017 
et  2019,  a  connu  une  amélioration  en  2021  avant  de  se  dégrader  en  2023.  La 
communication  en  temps  voulu  des  informations  sur  les  projections  des  émissions 
anthropiques de gaz à effet de serre par les sources et des absorptions par les puits de gaz 
à effets de serre s’est améliorée en 2019 par rapport à 2017, avant de se détériorer en 
2021.  

Accessibilité de l’information (par le public) 

Le  règlement  sur  la  gouvernance  a  amélioré  dans  une  certaine  mesure  l'accessibilité 
(publique) de l'information. Les parties prenantes ont souligné les limites de l'accessibilité 
du public à l'information, en particulier parce que celle-ci reste complexe et fournie dans 
un format qui n'est pas facile à utiliser. Toutefois, il n'est pas clair si ces problèmes sont 
liés au règlement sur la gouvernance en tant que tel ou, ce qui est plus probable, à des 
problèmes de mise en œuvre et/ou à des traditions nationales différentes au sein de l'UE.  

Processus de planification et mise en œuvre des plans  

Le  règlement  sur  la  gouvernance  a  permis  de  promouvoir  de  meilleurs  processus  de 
planification.   Par exemple, il a contribué à rationaliser les processus de planification dans 
les domaines de l'énergie et du climat, avec une coopération accrue  entre les différents 
ministères/autorités au niveau national. En ce qui concerne les PNEC en particulier, bien 
que le règlement sur la gouvernance ait amélioré la planification dans une certaine mesure, 
les PNEC ne sont pas toujours alignés sur les processus de planification nationaux et, dans 
ces cas, ils sont principalement élaborés pour répondre à une obligation de l'UE.  

Dans un certain nombre de cas, les traditions nationales en matière de planification ont pu 
avoir un impact négatif sur l'exhaustivité des SLT, les États membres ne communiquant 
pas tout le contenu obligatoire ou ne le faisant pas de manière cohérente avec leurs PNEC. 
De  même,  les  SLT  sont  en  partie  obsolètes  –  en  raison  de  l'absence  d'obligation  de  les 
mettre à jour – et ne servent pas nécessairement de base à l'élaboration des PNEC. Les 
parties  prenantes  ont  également  souligné  le  manque  d'attention  accordée  aux  SLT, 
notamment l'absence d'un processus de suivi étroit des SLT après leur adoption, comme 
c'est le cas pour les PNEC. 

En ce qui concerne la mise en œuvre, les autorités nationales consultées ont convenu que 
le  règlement  sur  la  gouvernance  a  contribué  à  l'adoption  ou  à  la  mise  en  œuvre  de 
politiques et de mesures visant à atteindre les objectifs nationaux en matière d'énergie et 
de climat. Dans le même temps, certains facteurs ont eu une incidence négative sur les 
processus de planification et sur la mise en œuvre effective des plans et des rapports (par 
exemple, l'absence de dispositions dans le règlement pour assurer la cohérence entre les 
PNEC et les SLT).  

Conformité 

Le règlement sur la gouvernance n’a été que partiellement efficace pour répondre à des 
manques  d’ambition  ou  des  lacunes  de  mise  en  œuvre.  L'un  des  principaux  facteurs 

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expliquant les déficits de mise en œuvre est que le mécanisme de conformité du règlement 
repose principalement sur des recommandations, qui n'ont pas de force contraignante.  

Stimuler les dépenses et les investissements  

Les consultations n'ont fourni qu'un retour d'information limité sur l'impact du règlement 
sur  la  stimulation  de  dépenses  et  d'investissements  ciblés  et  sur  la  création  d'une 
prévisibilité accrue pour les investisseurs. Néanmoins, les parties prenantes ont reconnu 
que le règlement fournit un cadre stable pour les entreprises d’énergies propres, ce qui, 
selon certains, est crucial pour l'investissement et le développement à long terme dans le 
secteur. 

Les  évaluations  de  la  Commission  montrent  que  les  PNEC  manquent  de  détails  sur  les 
besoins  d'investissement  et  les  sources  de  financement,  ce  qui  a  été  confirmé  par  les 
parties prenantes des secteurs économiques.  

Les  parties  prenantes  consultées  n'étaient  pas  toujours  au  courant  de  la  situation 
antérieure  au  règlement  sur  la  gouvernance  ou  n'étaient  pas  en  mesure  de  relier  ou 
d'attribuer  des  tendances  spécifiques  au  règlement  en  matière  de  dépenses  et 
d'investissements. 

Coopération régionale 

Tant  l'évaluation  des  projets  de  PNEC  des  États  membres  en  2019  que  l'évaluation  des 
PNEC finaux des États membres en 2020 ont indiqué qu'il était nécessaire de renforcer les 
efforts  de  coopération  régionale.    L'évaluation  de  2020  a  révélé  que,  bien  que  les  États 
membres aient correctement compris et décrit la nécessité d'une coopération régionale – 
certains  d'entre  eux  ayant  recours  aux  forums  régionaux  existants  –  le  potentiel  de  la 
coopération  régionale  n'a  pas  encore  été  pleinement  exploité.  L'évaluation  par  la 
Commission des progrès accomplis dans la réalisation des objectifs de l'union de l'énergie 
et de l'action climatique en 2023 a révélé que la plupart des États membres ont fait état 
de progrès dans la mise en œuvre de la coopération régionale, avec la plupart d'entre eux 
faisant état d'avancées dans au moins une de leurs initiatives ou un de leurs projets de 
coopération  régionale.  En  outre,  l'évaluation  des  projets  de  PNEC  à  l'échelle  de  l'UE  en 
2023  confirme  que  la  coopération  régionale  n'est  assurée  que  dans  une  mesure  limitée 
dans les États membres, et qu'elle se limite à des domaines spécifiques (par exemple, les 
accords bilatéraux sur la sécurité de l'approvisionnement en gaz).  

Garantie  d’un  dialogue  et  d’une  consultation multiniveaux  adéquats  impliquant 
une diversité de parties prenantes 

Les  données  disponibles  montrent  que,  bien  que  l'introduction  des  articles  10  et  11  du 
règlement  sur  la  gouvernance  soit  perçue  comme  un  progrès,  le  règlement  n'a  pas 
particulièrement  réussi  à  garantir  un  dialogue  et  une  consultation  adéquats  à  plusieurs 
niveaux  et  entre  plusieurs  parties  prenantes,  notamment  dû  au  fait  que  plusieurs  États 
membres n'aient pas réussi à mettre en place des mécanismes de qualité suffisante.      

Efficience  

L'analyse  d’efficience  donne  des  résultats  mitigés.  Le  règlement  a  rationalisé  certains 
aspects de la planification de la politique énergétique et du rapport d’informations, ce qui 
a  permis  à  certains  États  membres  de  réaliser  des  économies  de  temps  et/ou  de 
ressources.  Toutefois,  plusieurs  États  membres  ont  également  connu  une  augmentation 
de  la  charge  administrative.  Il  est  cependant  difficile  de  distinguer  la  charge  de  travail 
créée  par  le  règlement  de  celle  générée  par  les  aspects  organisationnels  des 
administrations  nationales  (y  compris  la  coordination  limitée  entre  les  personnes 
impliquées dans les obligations de rapport au niveau national), de l'évolution des cadres 

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législatifs nationaux/de l'UE et des obligations de rapport applicables indépendamment du 
règlement.  

Les  améliorations  reconnues  comme  introduites  par  le  règlement  sur  la  gouvernance 
comprennent une plus grande cohérence des calendriers et des procédures de planification 
et d'établissement de rapports, une transparence et une prévisibilité accrues, une meilleure 
coordination  transfrontalière,  une  coopération  renforcée  entre  les  autorités  nationales, 
ainsi  que  des  processus,  des  politiques  et  des  procédures  mieux  établis.  Même  si  les 
avantages ne se sont pas encore pleinement concrétisés, de nombreuses parties prenantes 
(en particulier au sein des autorités nationales) considèrent que le règlement pousse les 
administrations nationales à collaborer plus étroitement et à mettre en place de nouvelles 
procédures de coordination. 

Les  parties  prenantes  (en  particulier  les  autorités  nationales)  ont  également  reconnu 
l'existence d'une « courbe d'apprentissage » continue: si les premiers cycles de déclaration 
d’informations étaient relativement complexes, le processus devrait devenir plus facile et 
moins contraignant au fil du temps.  

Si  le  règlement  a  partiellement  rationalisé  les  processus  de  planification,  de  rapport 
d’informations et de suivi, il n'a pas permis une harmonisation complète et un alignement 
total  sur  le  calendrier  des  autres  obligations  européennes  et  internationales,  comme 
l'indiquent les réactions partagées des parties prenantes et les réponses à l'enquête. Les 
parties prenantes ont également fait remarquer qu'un délai de cinq ans pour les décisions 
stratégiques dans le secteur de l'énergie est insuffisant, car les changements significatifs 
dans  les  systèmes  énergétiques  nécessitent  généralement  une  planification  à  plus  long 
terme. En outre, les calendriers de certaines obligations (telles que la préparation des PNEC 
et  des  rapports  d’avancement  dans  une  succession  rapprochée)  ont  rendu  plus  difficile 
l’apprentissage  de  leçons  sur  la  base  des  cycles  de  planification  précédents.  En  outre, 
certaines obligations en matière de communication d’informations annuelle (en particulier 
celles  prévues  à  l'article  26)  pèsent  sur  les  ressources  des  États  membres  et  des 
institutions de l'UE. En ce qui concerne les obligations internationales, la principale difficulté 
réside  dans  le  fait  que  les  cadres  de  la  convention-cadre  des  Nations  unies  sur  les 
changements climatiques (CCNUCC) et de l'UE sur les émissions de GES prévoient toutes 
deux des obligations de déclaration biannuelle, mais à des dates différentes (années paires 
pour la CCNUCC et le rapport biannuel de transparence (BTR), et années impaires pour le 
rapport biannuel d’avancement en application du règlement sur la gouvernance). 

Le règlement a introduit des modèles communs pour les PNEC et les rapports d’avancement 
et  a  introduit  (dans  le  cas  de  ReportENER)  et  renforcé  (dans  le  cas  de  Reportnet)  des 
plateformes numériques. Des avis partagés ont été exprimés sur les gains de temps et/ou 
de  ressources  que  représentent  ces  modèles  et  plateformes  communs.  D'une  part,  les 
parties prenantes ont évoqué la nécessité de reformuler les données et les informations 
avant de les télécharger et ont noté que cela avait entraîné une augmentation des coûts. 
Elles ont  également souligné l'absence d'un outil permettant de compiler  et de partager 
des  réponses  complètes  provenant  de  différentes  autorités  au  sein  de  chaque  pays 
déclarant, et ont mentionné une connexion inadéquate entre les deux plateformes, ainsi 
que des différences de formats. 

D'autre part, certaines réductions de coûts et de charge administrative ont été réalisées, 
par  exemple  parce  que  ces  plateformes  apportent  une  plus  grande  clarté  sur  les 
informations et les données qui doivent être collectées et soumises. Elles évitent également 
aux États membres de devoir développer leurs propres outils nationaux et permettent à 
plusieurs  utilisateurs  d'accéder  simultanément  aux  informations.  Certaines  parties 
prenantes  ont  également  indiqué  que  les  deux  plateformes  jouent  un  rôle  dans  la 
standardisation  des  informations  communiquées  et  la  systématisation  de  la  collecte  des 
données, et facilitent la disponibilité et la comparabilité des informations.  

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Cohérence 

Le  règlement  a  amélioré  la  cohérence  des  obligations  en  matière  de  planification  et  de 
rapport d'informations qui étaient auparavant dispersées dans divers textes législatifs de 
l'UE dans les domaines de l'énergie, du climat et d'autres domaines politiques liés à l'union 
de l'énergie. Il reste cependant quelques incohérences qui affectent la cohérence interne 
et externe du règlement. 

Les  problèmes  de  cohérence  interne  sont  principalement  dus  à  la  complexité  de 
l'intégration  de  nombreuses  obligations  dans  un  cadre  juridique  unique,  ainsi  qu’aux 
changements juridiques connexes intervenus depuis l'adoption du règlement en 2018.  

Les questions de cohérence externe sont principalement liées à plusieurs instruments au 
niveau de l'UE qui ont été introduits et/ou mis à jour après 2018, notamment les diverses 
politiques développées dans le cadre du Pacte vert pour l’Europe. Par exemple, la refonte 
de  la  directive  sur  l'efficacité  énergétique  (DEE)  comprend  de  nombreux  nouveaux 
éléments  pour  une  gouvernance  plus  forte  qui  ne  sont  pas  actuellement  incorporés  ou 
rationalisés dans le règlement sur la gouvernance. De même, la directive révisée sur les 
énergies renouvelables (RED) a introduit de nouveaux éléments qui ne sont pas reflétés 
dans  le  règlement.  En  outre,  il  est  possible  d'aligner  davantage  d'autres  obligations  en 
matière de planification/déclaration, telles que le cycle de rapport de la CCNUCC, sur celles 
du règlement.  

Valeur ajoutée de l’UE 

Le règlement a renforcé la cohérence des politiques nationales en matière d'énergie et de 
climat, ainsi que leur planification, bien que l'impact ait varié d'un État membre à l'autre, 
en partie en raison de la diversité des processus nationaux antérieurs au règlement. Les 
parties  prenantes  ont  également  souligné  que  la  coordination  avec  les  acteurs 
infranationaux  est  un  domaine  dans  lequel  la  valeur  ajoutée  du  règlement  pourrait  être 
davantage renforcée. 

Les obligations de planification et de rapport d’informations prévues par le règlement ont 
donné  lieu  à  des  données  supplémentaires  au  niveau  de  l'UE  et  au  niveau  national.  En 
exigeant  des  États  membres  qu'ils  publient  des  rapports  et  des  données  qu'ils  ne 
collectaient ou ne  communiquaient pas auparavant, le règlement a accru la disponibilité 
des  informations  et  a  également  apporté  une  valeur  ajoutée  en  permettant  aux  parties 
prenantes,  y  compris  les  autorités  des  États  membres  et  la  Commission  européenne, 
d'accéder aux plans et aux évaluations d'autres États membres. De plus, le règlement a 
clairement amélioré la gestion des données relatives à l'énergie et au climat dans l'UE, en 
favorisant un cadre plus clair et plus ouvert pour le partage d'informations et la prise de 
décisions. Néanmoins, les parties prenantes ont souligné les problèmes liés à la soumission 
en temps voulu, à la qualité (en termes d'exhaustivité), à l'accessibilité et à la transparence 
des données communiquées.  

Les  avis  divergent  sur  la  valeur  ajoutée  du  règlement  en  termes  de  responsabilité  et 
d'accès à la justice, certaines parties prenantes (principalement les autorités nationales) 
soulignant les effets positifs et d'autres (principalement les parties prenantes du troisième 
secteur) considérant que des améliorations significatives sont encore nécessaires dans ce 
domaine.  

Pertinence 

L'objectif principal du règlement sur la gouvernance, qui est de fournir une structure de 
gouvernance  permettant  aux  États  membres  de  s'engager  à  atteindre  des  objectifs 
ambitieux en matière d'énergie et de climat et les incitant à le faire, reste pertinent et l'est 
même devenu davantage compte tenu de la nécessité croissante d'agir pour le climat et 

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des besoins de plus en plus complexes auxquels les politiques énergétiques et climatiques 
des États membres doivent répondre. Alors que les perspectives du changement climatique 
et de ses conséquences s'aggravent et se précisent, l'objectif principal du règlement sur la 
gouvernance – permettre et soutenir l'action climatique et l'union de l'énergie – est plus 
que jamais d'actualité. 

Depuis l'adoption du règlement sur la gouvernance en 2018, l'acquis de l'UE en matière 
d'énergie  et  de  climat  a  connu  d'importantes  évolutions,  notamment  le  paquet  « 
Ajustement à l’objectif 55 ». En tant que cadre principalement procédural qui ne fixe pas 
lui-même  d'objectifs  spécifiques,  cela  n'a  pas  rendu  le  règlement  sur  la  gouvernance 
obsolète en tant qu'instrument. Toutefois, certaines questions reflétées dans la législation 
récente  doivent  être  mieux  prises  en  compte  dans  les  résultats  obtenus  au  titre  du 
règlement, y compris les PNEC. 

Enfin,  le  règlement  n'aborde  pas  de  manière  adéquate  certaines  des  questions  qui  sont 
devenues  plus  importantes  à  la  suite  de  l'agression  russe  contre  l'Ukraine,  telles  que  la 
sécurité énergétique et la nécessité d'une industrie compétitive des énergies propres. La 
crise de l'approvisionnement énergétique et la pandémie de COVID-19 ont toutes deux mis 
en évidence les défis sociaux et économiques qui doivent être relevés pour atteindre les 
objectifs  du  changement  climatique  et  d’une  transition  équitable  à  long  terme.  Les 
réactions des parties prenantes suggèrent que les questions socio-économiques, telles que 
la précarité énergétique et les pénuries de main-d'œuvre, ne sont pas traitées de manière 
adéquate  par  le  règlement.  Cette  insuffisance  est  exacerbée  par  l'absence  d'évaluations 
macroéconomiques solides des mesures incluses dans les PNEC. 

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List of abbreviations and acronyms 

BRP(s) 

BTR 

CAP 

CBAM 

CCS 

CfE 

COP 

CRF 

CSP(s) 

CSR(s) 

DG(s) 

Building Renovation Plan(s) 

Biennial transparency report 

Common Agricultural Policy 

Carbon Border Adjustment Mechanism 

Carbon capture and storage 

Call for Evidence 

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

Common reporting format 

Common Agricultural Policy Strategic Plan(s) 

Country-specific recommendation(s) 

Directorate(s)-General 

DG CLIMA 

Directorate-General for Climate Action 

DG ENER 

Directorate-General for Energy 

DNSH 

Do no significant harm principle 

EEA 

EED 

EEF 

Eionet 

EPBD 

EQ(s) 

ESD 

ESR 

ESTAT 

ETC(s) 

European Environment Agency 

Energy Efficiency Directive (Directive 2012/27/EU) 

Energy efficiency first principle 

European Environment Information and Observation Network  

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 

European Topic Centre(s) 

ETC/CME 

European Topic Centre – Climate change Mitigation and Energy 

ETS 

EU  

Emissions Trading System 

European Union 

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EUR 

FEC 

FTE 

GHG  

HFC(s) 

IA 

IPCC 

IT 

Euro 

Final energy consumption 

Full-time equivalent 

Greenhouse gas 

Hydrofluorocarbon(s) 

Impact assessment 

Intergovernmental Panel on Climate Change 

Information technology 

IWG(s)  

Implementation Working Group(s) 

JTF 

KII(s) 

KPI(s) 

Just Transition Fund 

Key informant interview(s) 

Key performance indicator(s) 

LTRS(s)  

Long-Term Renovation Strategy(ies) 

LTS(s) 

LULUCF  

MMR 

MRV 

NCA(s) 

NDC 

NECP 

Long-Term Strategy(ies) 

Land Use, Land Use Change and Forestry 

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

Monitoring, reporting and verification 

National competent authority(ies) 

Nationally determined contributions 

National Energy and Climate Plan 

NECPR(s) 

National Energy and Climate Progress Report(s) 

NEEAP(s)  

National Energy Efficiency Action Plan(s) 

NGO(s) 

NZIA 

PaM(s)  

PEC 

PFC(s)  

PV 

Non-governmental organisation(s) 

Net Zero Industry Act 

Policies and measure(s) 

Primary energy consumption 

Perfluorocarbon(s) 

Photovoltaics 

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QA 

QC 

R&I 

RDI 

RED 

REFM 

RES 

RFNBOs 

RRF 

RRP(s)  

SEA 

Quality assurance 

Quality control 

Research and innovation 

Research, development and innovation 

Renewable Energy Directive (Directive (EU) 2018/2001) 

Renewable Energy Financing Mechanism 

Renewable energy sources 

Renewable fuels of non-biological origin 

Recovery and Resilience Facility 

Recovery and Resilience Plan(s) 

Strategic environmental assessment 

SECAP(s)  

Social, Environmental and Climate Assessment Plan(s) 

SET 

Strategic Energy Technology 

SDG(s)  

Sustainable Development Goal(s) 

SWD 

TFEU 

Staff Working Document 

Treaty on the Functioning of the European Union 

TSO(s)  

Transmission System Operator(s) 

UN 

United Nations 

UNFCCC 

United Nation Framework Convention on Climate Change 

WAM 

WEM 

WOM 

‘With additional measures’ scenario 

‘With existing measures’ scenario 

‘Without measures’ scenario 

EU Member States 

AT 

Austria 

EL 

Greece 

LV 

Latvia 

BE 

Belgium 

FI 

Finland 

MT  Malta 

BG  Bulgaria 

FR 

France 

NL 

Netherlands 

CY 

Cyprus 

HR 

Croatia 

PL 

Poland 

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CZ 

Czechia 

HU  Hungary 

PT 

Portugal 

DE  Germany 

IE 

Ireland 

RO 

Romania 

DK  Denmark 

IT 

Italy 

SE 

Sweden 

EE 

Estonia 

LT 

Lithuania 

SI 

Slovenia 

ES 

Spain 

LU 

Luxembourg 

SK 

Slovakia 

Third countries 

CH  Switzerland 

IS 

Iceland 

NO  Norway 

UK  United Kingdom  

US  United States of America 

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Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the 
Energy Union and Climate Action 

1 

INTRODUCTION  

This  is  the  Final  Evaluation  Report  of  the  study  providing  Support  in  the  Evaluation  of 
Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action, an 
assignment undertaken by ICF SA (ICF) in collaboration with Fraunhofer ISI, Cambridge 
Econometrics, Institute for European Energy and Climate Policy (IEECP) and Aether, and 
on  behalf  of  the  European  Commission  Directorates-General  for  Energy  (DG  ENER)  and 
Climate Action (DG CLIMA). The Study was launched by DG ENER and DG CLIMA on 16 
June  2023,  under  Framework  Contract  CLIMA.A4/FRA/2019/0011,  with  the  specific 
contract No ENER/A1/2022-379/SI2.897173.  

This  Final  Evaluation  Report  presents  the  results  of  the  evaluation.  It 
summarises  the  methodological  approach,  obstacles  encountered  and/or 
overcome,  and  limitations  of  the  research.  It  draws  on  the  results  of  desk 
research, multi-strand stakeholder consultation, a comprehensive mapping of 
legal obligations pertaining to the Governance Regulation, and in-depth case 
studies in seven Member States. The report provides answers to each of the 
evaluation questions.  

This Final Evaluation Report is informed by: 

  In-depth  desk  research  between  June  2023  and  February  2024,  which  covered  a 
wide variety of sources from across the 27 European Union Member States (EU-27) 
and beyond. 

  In-depth analysis of the responses to the Call for Evidence (CfE) conducted by the 

European Commission between July and August 2023 (see Annex 6). 

  Online  targeted  surveys  of  Member  State  authorities,  industry  and  third  sector 

organisations by ICF between October and November 2023 (see Annex 6). 

  Targeted  telephone/video  interviews  with  key  stakeholders  during  the  study 
inception phase, main interview programme, and in support of the case studies (see 
Annex 6). 

  Findings from the case studies on seven Member States (Belgium, Denmark, France, 

Germany, Malta, Romania, Poland) (see Annex 5). 

  Feedback  from  the  stakeholder  event  conducted  by  the  European  Commission  in 

Brussels on 11 January 2024 (see Annex 6).   

This Final Evaluation Report is structured as follows:  

  Section 1 Introduction: Explains the context, purpose, and scope of the evaluation. 
  Section 2 Methodological approach to the evaluation: Explains the methodological 
approach,  obstacles  encountered  and/or  overcome,  and  limitations  of  the  data 
collection and analysis. 

  Section  3  What  was  the  expected  outcome  of  the  Governance  Regulation?: 
Articulates the expected outcomes of the Governance Regulation. It is underpinned 
by an intervention logic diagram and also presents the baseline for the evaluation. 
  Section 4 How has the situation evolved over the evaluation period?: Describes the 
main  policy  and  other  (e.g.  geopolitical)  developments  that  occurred  over  the 
evaluation period and may have influenced, directly or indirectly, the functioning of 
the Governance Regulation and thus the evaluation findings. 

  Section  5  Findings  of  the  evaluation:  Explains  the  findings  of  the  evaluation, 

drawing on all data collection and consultation activities carried out. 

  Section 6 Conclusions and lessons learned: Presents the main conclusions from the 

study, as well as lessons from the evaluation of the Governance Regulation. 

The following documents are annexed to this Final Evaluation Report: 

  Annex 1: Methodological approach and limitations  
  Annex 2: Short summary on the feedback to the CfE 

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  Annex 3: Detailed method of the efficiency analysis  
  Annex 4:  Evaluation framework 
  Annex 5: Case studies 
  Annex 6: Synopsis Report  
  Annex 7: Classification of obligations from energy and climate acquis included in 

the Governance Regulation (baseline) 

The  annexes  are  provided  separately  and  submitted  jointly  with  this  Final  Evaluation 
Report.  

1.1  Background and context  

On  24  October  2014,  the  European  Council  endorsed  a  2030  Climate  and  Energy 
Framework for the Union1, establishing four EU-level targets: 

a reduction of at least 40 % in gross economy-wide greenhouse gas (GHG) emissions; 

an indicative target of improvement in energy efficiency of at least 27 %, to be reviewed 
by 2020 with a view to increasing the level to 30 %; 

a share of renewable energy consumed in the Union of at least 27 %; and 

electricity interconnection of at least 15 %. 

On  25  February  2015,  the  European  Commission  published  its  Strategy  for  a  European 
Energy Union 2, a key priority of the Juncker Commission (2014-2019). The Energy Union 
Strategy aimed to build an Energy Union that gives EU consumers, including households 
and businesses, secure, sustainable, competitive, and affordable energy.  

On 5 October 2016, the European Council published its Decision (EU) 2016/1841 on the 
conclusion, on behalf  of the European Union, of the Paris Agreement adopted under the 
United Nations Framework Convention on Climate Change (UNFCCC),3 paving the way for 
the  adoption  of  the  Governance  of  the  Energy  Union  and  Climate  Action  Regulation 
(Regulation (EU) 2018/1999, Governance Regulation),4 in 2018.  

The  Governance  Regulation  aimed  to  ensure  that  the  Energy  Union  Strategy  is 
implemented  in  a  coordinated  and  coherent  manner  across  its  five  dimensions.  It  also 
sought to ensure that the EU achieves its objectives, in particular the targets of the 2030 
Climate and Energy Framework and the Paris Agreement on climate change.  

Alongside the adoption of the Governance Regulation, the recast Directive 2018/2001/EC 
(Renewable Energy Directive, RED) introduced a new and binding renewable energy target 
for the Union for 2030 of at least 32 %, including a provision for a review with a view to 
increasing the Union-level target by 2023. Since that time, and since the adoption of the 
Governance  Regulation  in  2018,  the  European  and  global  energy  and  climate  policy 
landscape  has  undergone  a  significant  transformation  (Figure  1).  The  shifts  partly  stem 

a 

Policy 

and  Energy 

Framework,  EUCO  169/14,  2014, 

1  European  Council,  2030  Climate 
https://data.consilium.europa.eu/doc/document/ST-169-2014-INIT/en/pdf 
2  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social Committee, the Committee of the Regions and the European Investment Bank, A Framework Strategy for 
a  Resilient  Energy  Union  with 
Policy,  COM/2015/080, 
https://energy.ec.europa.eu/topics/energy-strategy/energy-union_en?redir=1  
3 Council Decision (EU) 2016/1841 on the conclusion, on behalf of the European Union, of the Paris Agreement 
adopted under the United Nations Framework Convention on Climate Change,  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=celex%3A32016D1841 
4  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,  amending  Regulations  (EC)  No  663/2009  and  (EC)  No 
715/2009 of the European Parliament and of the Council, Directives 94/22/EC, 98/70/EC, 2009/73/EC, 20131/EU, 
2012/27/EU and 2013/30/EU of the European Parliament and of the Council, Council Directives 2009/119/EC and 
(EU)  2015/652  and  repealing  Regulation  (EU)  No  525/2013  of  the  European  Parliament  and  of  the  Council, 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32018R1999 

Forward-looking  Climate  Change 

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Energy Union and Climate Action 

from the unprecedented crisis situations of the COVID-19 pandemic and Russia’s war of 
aggression against Ukraine, as well as policy developments independent of these factors, 
including the European Green Deal and its new policies and regulations, such as the Fit for 
55 package and the European Climate Law.  

Figure 1.  Legislative timeline following the adoption of the Governance Regulation  

Source: ICF, based on COM(2022) 5475 and 2022/C 495/026. 

Russia’s  war  of  aggression  against  Ukraine  and  manipulation  of  fuel  supplies  and  prices 
contributed to a significant rise in energy prices across the EU. The energy price peak (in 
August 2022) led to a significant increase in the cost of living for citizens and reduced the 
global competitiveness of EU industry7. Coordinated action by the EU, including Regulation 
(EU) 2023/435 (REPowerEU)8 and emergency legislative initiatives under Article 122 of the 
Treaty on the Functioning of the European Union (TFEU) adopted in 2022 helped to mitigate 
the  effects  of  the  energy  crisis  for  households  and  industry9.  At  the  same  time,  the 
temporary  spike  in  energy  prices  highlighted  the  need  for  effective  crisis  response  and 
supply  diversification  across  the  energy  sector.  This  reinforced  the  significance  of  the 
Governance Regulation as the cornerstone for coordinated energy and climate action at EU 
level through the National Energy and Climate Plans (NECPs). 

The Governance Regulation has been amended by several acts since its adoption in 2018. 
In  2021,  Regulation  (EU)  2021/1119  (European  Climate  Law)  amended  the  Governance 

plans, 

2022/C 

5  Report  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions, State of the Energy Union, COM(2022), 547 final,  https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52022DC0547&from=en    
6 Commission Notice on the Guidance to Member States for the update of the 2021-2030 national energy and 
climate 
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52022XC1229(02)    
7  Report  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions,  State  of  the  Energy  Union  Report  COM(2023),  650  final, 
https://eur-lex.europa.eu/resource.html?uri=cellar:b27b8b93-725d-11ee-9220-
01aa75ed71a1.0001.02/DOC_1&format=PDF 
8 Regulation (EU) 2023/435 
9  Report  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions,  State  of  the  Energy  Union  Report  COM(2023),  650  final 
https://eur-lex.europa.eu/resource.html?uri=cellar:b27b8b93-725d-11ee-9220-
01aa75ed71a1.0001.02/DOC_1&format=PDF 

495/02, 

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Energy Union and Climate Action 

Regulation to include the climate-neutrality objective in the relevant provisions and give 
the Commission a mandate to prepare a methodology for reporting on the phase-out of 
energy subsidies, notably for fossil fuels. The Governance Regulation was also updated by 
the Fit for 55 amendments of Regulation (EU) 2018/842 (Effort Sharing Regulation, ESR), 
Regulation (EU) No 2018/841 (Land Use, Land Use Change and Forestry, LULUCF) and RED 
to  align  it  with  changed  ESR  and  LULUCF  review  processes.  Finally,  the  Union’s  energy 
efficiency targets in the Governance Regulation were amended by Decision (EU) 2019/504, 
following the withdrawal of the United Kingdom (UK) and Northern Ireland from the EU10.  

According to Article 1(1)(c) of the Governance Regulation, one of its objectives is to ensure 
the timeliness, transparency, accuracy, consistency, comparability, and completeness  of 
reporting  by  the  Union  and  its  Member  States  to  the  UNFCCC  and  Paris  Agreement 
Secretariat. Chapter 4 of the Governance Regulation provides specific rules on reporting, 
including  biennial  progress  reports  and  their  follow-up  (section  1)  and  annual  reporting 
(section 2). Such reporting needs to be  robust, objective and based  on the most up-to-
date and scientifically and technically sound data. The goal of these reporting exercises is 
to  allow  the  European  Commission  to  assess  whether  the  Union  is  on  track  to  meet  its 
goals, including the 2030 climate targets and the 2050 climate-neutrality objective. The 
reporting also seeks to enable the EU to fulfil its international reporting obligations under 
the UNFCCC and Paris Agreement.  

The Energy Union covers five core dimensions: energy security; internal energy market; 
energy efficiency; decarbonisation; and research, innovation and competitiveness.  When 
the Governance Regulation was first conceived, its primary focus was on addressing issues 
of energy efficiency, renewable energy, and decarbonisation. Developments have led to a 
broadening  of  policy  focus  in  the  EU  to  include  issues  such  as  the  security  of  the  EU’s 
energy  supply, EU  competitiveness, and the just transition. A  review  of the Governance 
Regulation and its functioning is especially important in view of these developments. Other 
important developments to be considered in the review include the Net Zero Industry Act 
(NZIA)11, the Hydrogen Bank12, and the European Critical Raw Materials Act13. Additional 
elements include: 

  Ensuring  coherence  between  the  European  Green  Deal,  including  the  European 

Climate Law and the Governance Regulation. 

  Improving synergies between the Governance  Regulation,  climate  adaptation and 
environmental policies (e.g. Zero Pollution Action Plan, the Circular Economy Action 
Plan, the Biodiversity Strategy, the Forest Strategy). 

  Ensuring  appropriate  coverage  of  all  aspects  of  the  transition  in  the  Governance 
Regulation, including just transition, security of energy supply and internal energy 
market. 

  The role of the land-use and technological sectors in emissions and removals.  
  Ensuring the provision of robust and detailed information on the investment needs 
to achieve the objectives and targets of the NECPs and the sources of their financing, 
as  the  implementation  of  the  NECPs  will  be  increasingly  important  approaching 
2030. 

10 As these were expressed as absolute values of energy consumption, they had to be adjusted for the changed 
scope. 
11 Net Zero Industry Act, https://single-market-economy.ec.europa.eu/publications/net-zero-industry-act_en 
12 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions on the European Hydrogen Bank, COM/2023/156 final,  

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52023DC0156&qid=1689756932873 
13  European  Critical  Raw  Materials  Act,  https://commission.europa.eu/strategy-and-policy/priorities-2019-
2024/european-green-deal/green-deal-industrial-plan/european-critical-raw-materials-act_en 

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  Member States’ provision of robust macro-economic impacts of their NECPs, given 
the relevance of the energy and climate transition and its impact on public finances. 
  Future-proofing the Governance Regulation to make it fit for purpose from a 2040 
and  2050  policy  perspective  and  beyond,  including  ensuring  alignment  with  Paris 
Agreement developments.  

  Rationalising  the  administrative  burden  associated  with  planning,  reporting  and 

monitoring obligations. 

1.2  Purpose and scope of the evaluation 

The  objective  of  this  study  is  to  support  the  European  Commission  in  conducting  an 
evaluation of the  Governance Regulation. The study findings are expected to inform the 
report submitted by the Commission to the European Parliament and Council, as per Article 
45 of the Governance Regulation. The scope of the study is broader than the review clause 
of Article 45 so as to ensure alignment of the evaluation with Better Regulation criteria.  

The study analyses how the Governance Regulation has been implemented since 2018 (ex-
post  evaluation),  based  on  the  Better  Regulation  criteria  of  effectiveness,  efficiency, 
relevance,  coherence,  and  EU  added  value14.  In  terms  of  geographical  scope,  the  study 
focuses  on  the  EU-27.  Although  the  climate  element  of  the  Governance  Regulation  also 
applies to Norway and Iceland, they were not included in the data collection or consultation 
processes15.  

2  METHODOLOGICAL APPROACH TO THE EVALUATION 

The  research  for  this  report  was  conducted  between  July  2023  and  February  2024.  It 
comprised:  comprehensive  desk  research;  legal  mapping  of  planning,  reporting  and 
monitoring  obligations  stemming  from  the  Governance  Regulation;  CfE  (by  the 
Commission); an online survey of national authorities, industry representatives and third 
sector  organisations  (led  by  ICF);  telephone  interviews  (led  by  ICF);  and  a  stakeholder 
event  in  Brussels  (organised  by  the  Commission).  A  more  detailed  explanation  of  the 
methodological  approach  to  the  evaluation  is  given  in  Annexes  1,  3  and  5,  while  an 
intervention logic for the Governance Regulation is provided in section 3.1.  

3  WHAT  WAS  THE  EXPECTED  OUTCOME  OF  THE  GOVERNANCE 

REGULATION? 

3.1  Intervention logic of the Governance Regulation 

Figure 2 summarises the reasons the Governance Regulation was proposed and adopted 
(intervention logic). It shows how the Governance Regulation was expected to work, the 
needs it sought to address, and its main objectives. It also describes the broader policy 
context  of  the  Governance  Regulation,  including  other  EU  energy  and  climate-related 
policies  and  legislation,  EU  legislation  and  policy  in  related  domains,  and  relevant 
international obligations. Figure 2 shows the logical and causal relationships between the 
resources  (inputs)  and activities  required  to  implement  the  Governance  Regulation,  and 
the outputs, results, and longer-term impacts of performing the activities. It also shows 
the external factors that may have influenced how the Regulation worked in practice.  

14 https://commission.europa.eu/system/files/2023-02/br_toolbox-nov_2021_en.pdf 
15 Switzerland reports (voluntarily) the same part of the Governance Regulation reported by Norway and Iceland. 
In  addition,  the  countries  of  the  Energy  Community  have  an  adapted  Governance  Regulation.  Although  not 
included in the analysis, the Governance Regulation indirectly affects these countries. 

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Energy Union and Climate Action 

The  general  objectives  of  the  Governance  Regulation  were  defined  by  the  European 
Commission’s  in  its  Impact  Assessment  (IA)  accompanying  the  proposal  for  the 
Governance Regulation (SWD(2016) 394 final)16. These can be summarised as follows: 

To ensure a coordinated and coherent implementation of the Energy Union Strategy across 
its  five  dimensions,  as  well  as  the  collective  achievement  of  Energy  Union  objectives 
through a combination of EU and national measures; 

To establish a functional (dynamic, reliable and transparent) governance process between 
the Commission and Member States; 

To minimise administrative burden and achieve a simplification and integration of planning, 
reporting  and  monitoring  obligations  for  Member  States  and  the  Commission,  while 
maintaining  benefits  of  such  obligations,  including  their  quality  of  information  and 
transparency; 

To ensure EU compliance with its international climate obligations, especially those deriving 
from the UNFCCC and the Paris Agreement. 

Article 1 sets out the specific objectives of the Governance Regulation:  

  To implement strategies and measures designed to meet the objectives and targets 
of  the  Energy  Union  and  the  long-term  Union  GHG  emissions  commitments 
consistent with the Paris Agreement, and for the first 10-year period, from 2021 to 
2030, in particular the Union's 2030 targets for energy and climate; 

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

  To  contribute  to  greater  regulatory  and  investor  certainty  and  help  to  take  full 
advantage of opportunities for economic development, investment stimulation, job 
creation and social cohesion. 

Inputs  can  be  understood  as  the  technical,  financial,  and  human  resources  used  by  all 
stakeholders to implement the Governance Regulation. This includes the resources used 
by the European Commission to establish the energy and climate governance process at 
EU  level,  such  as  providing  technical  support  and  guidance  to  Member  States,  issuing 
implementing acts and guidelines on reporting requirements under the Regulation, drafting 
country-specific recommendations (CSRs) on draft NECPs, cooperating with the European 
Environment Agency (EEA), hosting and maintaining the online platform (e-platform), and 
overseeing the workings of the Climate Change and Energy Union Committees.  

Inputs  also  include  the  technical,  financial  and  human  resources  used  by  the  Member 
States to meet their planning and reporting obligations (e.g. for the purpose of preparing, 
adopting,  notifying  and  assessing  NECPs;  establishing  multi-level  climate  and  energy 
dialogues at national level).  

The  activities  describe  the  (tangible)  day-to-day  actions  taken  by  stakeholders  to 
implement the provisions of the Governance Regulation: 

  Member State actions to establish integrated NECPs (chapter 2) and LTSs (chapter 

3); 

16  European  Commission,  Impact  Assessment  accompanying  the  document  Proposal  for  a  Regulation  of  the 
European  Parliament  and  the  Council  on  the  Governance  of  the  Energy  Union,  amending  Directive  94/22/EC, 
Directive 98/70/EC, Directive 2009/31/EC, Regulation (EC) No 663/2009, Regulation (EC) No 715/2009, Directive 
2009/73/EC, Council Directive 2009/119/EC, Directive 2010/31/EU, Directive 2012/27/EU, Directive 2013/30/EU 
and  Council  Directive  (EU)  2015/652  and  repealing  Regulation  (EU)  No  525/2013,  SWD(2016)  394  final,  
https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52016SC0394&from=FR 

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  Member State actions to report to the European Commission and UNFCCC on the 

implementation of their plans, policies and measures (PaMs) (chapter 4); 

  European  Commission  actions  to  monitor  progress  towards  meeting  the  agreed 

objectives and targets at EU and Member State level (chapter 5); 

  European  Commission  and  Member  State  actions  to  establish  GHG  inventory 

systems (Chapter 6); 

  Member  State  actions  to  cooperate  with  each  other  and  with  the  European 

Commission (Chapter 7). 

Stemming from the activities, the outputs of the Governance Regulation include the various 
planning, reporting, and monitoring documents and information, including the NECPs and 
LTSs, the NECPRs, integrated reporting on GHG PaMs and projections.  

Results refer to the Regulation’s expected immediate effects, including:  

  More  and  better  quality  quantitative  data/statistics,  as  well  as  complementary 

qualitative information; 

  Transparency on planned measures, investments, policies, market trends;  
  Greater regulatory certainty, predictability; 
  Timely transparency on implementation by Member States; 
  More efficient reporting processes, easier reuse, and integration;  
  Improved 

coordination/planning/communication/knowledge-sharing 

between 

Member States, the Commission, and other stakeholders. 

Outcomes capture the Regulation’s expected medium-term effects, including: 

  Coherence and adequacy of PaMs at Union and national level;  
  Improved capacity to track progress towards targets and take appropriate measures 

on time; 

  Better compliance with legislation; 
  More evidence-based national and EU policies;  
  Improved  investor  confidence,  increased  investment,  and  more  efficient  public 

support. 

At the end of the logic chain are the expected impacts of the intervention, which  should 
align with the initial needs. The impacts considered in the intervention logic are:  

  Contribution to the achievement of the five objectives of the Energy Union:  

1. Energy security; 

2. Internal energy market; 

3. Energy efficiency; 

4. Decarbonisation; 

5. Research, innovation, and competitiveness.  

  Contribution  to  the  Union’s  GHG  emission  reduction  objectives  and  targets, 
consistent  with  the  Paris  Agreement,  as  well  as  its  renewable  energy  and  energy 
efficiency targets. 

The intervention logic also refers to three categories of other interventions relevant to the 
Governance Regulation:   

  Other  EU  energy  and  climate  acquis,  such  as  obligations  stemming  from  the 
European Climate Law and other relevant parts of the European Green Deal, the Fit 
For 55 legislative package, REPowerEU, the EED and RED, and the ESR. 

  Other  relevant  EU  policy  fields:  the  European  Semester,  Recovery  and  Resilience 
Facility (RRF) and national Recovery and Resilience Plans (RRPs), Zero Pollution Plan 
(including  air  quality  plans),  Circular  Economy  Action  Plan,  Biodiversity  Strategy, 
Forest Strategy, Common Agriculture Policy (CAP) Strategic Plans, Just Transition 

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Fund (JTF) and Plans, EU Adaptation Strategy, transport and industrial policy, and 
other  relevant  strategic  planning  processes.  In  the  future,  national  biodiversity 
strategies  and  action  plans  under  the  UN  Convention  on  Biological  Diversity  and 
national restoration plans under the Nature Restoration Law may also be relevant. 
  International obligations, including those stemming from the Paris Agreement and 

UN Sustainable Development Goals (SDGs). 

The Governance Regulation policy context is also influenced by certain exogenous factors, 
such  as  Russia’s  war  of  aggression  against  Ukraine  and  the  ensuing  energy  crisis,  that 
could impact its ability to achieve its stated objectives.  

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Figure 2.  Intervention logic for the Governance Regulation 

Source: ICF elaboration.  

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Energy Union and Climate Action 

3.2  Baseline for the evaluation  

Defining  the  baseline  is  a  crucial  step  in  any  policy  evaluation,  as  the  benchmark  or 
reference point against which the effectiveness, efficiency, relevance, coherence, and EU 
added value of the intervention is assessed. Comparing changes against this baseline is an 
important  step  in  determining  (or  eliminating)  any  causal  relationships  between  the 
intervention and observed outcomes and impacts.  

In  this  evaluation,  the  baseline  is  the  situation  immediately  before  the  Governance 
Regulation  entered  into  force.  Establishing  the  baseline  requires  information  on  key 
indicators  and  metrics  that  reflect  the  situation  before  the  start  of  the  initiative  (Better 
Regulation Toolbox, Tool #60). It then assesses the intervention against this baseline and 
the key points of comparison relevant to the evaluation criteria and questions.  

As the Governance Regulation sought (among other things) to rationalise and streamline 
planning  and  reporting  obligations  in  pre-existing  legislation,  a  key  step  in  defining  the 
baseline was to identify the legislation that preceded the Regulation.  

The analysis of the energy and climate acquis carried out when the Commission prepared 
its Governance Regulation proposal17 formed the starting point for developing the baseline 
(see Annex 7). The analysis encompassed 20 different pieces of legislation for the energy 
acquis and one piece of legislation  for the climate acquis (Regulation  (EU) No 525/2013 
(Monitoring Mechanism Regulation, MMR)). With a few exceptions, all obligations that were 
indicated  for  integration  made  their  way  into  the  Governance  Regulation,  while  those 
indicated  for  repeal  were  repealed  from  sectoral  legislation  and  removed  from  the  EU 
energy  and  climate  acquis.  Finally,  obligations  recommended  to  be  kept  separate  were 
maintained as independent obligations, in either general or sectoral legislation.  

Of the 76 obligations the Commission identified as relevant for the Governance Regulation, 
54  concern  obligations  included  in  energy  legislation  (from  20  different  pieces  of 
legislation) and 22 in climate legislation (all from the MMR).  

Overall, 68 of the 76 obligations were classified, as follows:  

  15 planning obligations (all energy-related); 
  29 reporting obligations (16 energy-related; 13 climate-related); 
  2 planning and reporting obligations (one energy-related; one climate-related);   
  22 monitoring obligations (all energy acquis).  

The  remaining  eight  obligations  under  the  climate  acquis  cannot  be  assigned  to  either 
planning and/or reporting and/or monitoring types and are instead classified as ‘others’ 18. 
Within the 54 energy-related obligations, 22 target the Commission and 26 the Member 
States. Four of the remaining obligations target transmission systems operators (TSOs) in 
relation to the Electricity Directive, the Gas Directive, the Network Access for Cross-Border 
Electricity  Exchanges  Regulation,  and  the  Network  Access  for  Natural  Gas  Transmission 
Regulation. The final two obligations target the European Network of Transition Operators 
for Energy (ENTSO-E), in relation to Network Access for Cross-Border Electricity Exchanges 

17  European  Commission,  Impact  Assessment  accompanying  the  document  Proposal  for  a  Regulation  of  the 
European  Parliament  and  the  Council  on  the  Governance  of  the  Energy  Union,  amending  Directive  94/22/EC, 
Directive 98/70/EC, Directive 2009/31/EC, Regulation (EC) No 663/2009, Regulation (EC) No 715/2009, Directive 
2009/73/EC, Council Directive 2009/119/EC, Directive 2010/31/EU, Directive 2012/27/EU, Directive 2013/30/EU 
and  Council  Directive  (EU)  2015/652  and  repealing  Regulation  (EU)  No  525/2013,  SWD(2016)  394  final,  
https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52016SC0394&from=FR 
18  These  eight  ‘other’  obligations  vary  in  nature,  encompassing:  obligations  related  to  the  procedures  for 
completing  emission  estimates  to  compile  the  Union  inventory  (gap  filling);  obligations  on  the  review  of  GHG 
inventories for the purposes of Decision No 406/2009/EU (Effort Sharing Decision, ESD) and on addressing the 
effects of recalculations in the ESD; and more ‘organisational’ provisions on cooperation between Member States 
and the Union, and the role of the European Environment Agency and Climate Change Committee to assist the 
Commission.  

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Regulation,  and  the  European  Network  of  Transition  Operators  for  Gas  (ENTSO-G),  in 
relation to the Network Access for Natural Gas Transmission Regulation, respectively. Of 
the 54 relevant energy-related obligations (a sub-set of the 76 obligations in scope), 18 
were integrated into the Governance Regulation, most (13) related to energy efficiency, 
while the remaining four related to decarbonisation and the internal energy market. The 
same  number  of  obligations  (18)  were  repealed,  most  relating  to  the  internal  energy 
market (11) and energy efficiency (four). Other obligations (11) were kept separate but 
still reflected in the Governance Regulation, primarily as part of the internal energy market 
dimension (five), but also within the energy security (three) and energy efficiency (one) 
dimensions.  

The 22 relevant obligations contained in climate legislation (from the MMR) all fall under 
the  decarbonisation  dimension.  All  but  one  were  integrated  into  the  Governance 
Regulation. Of the 22, eight target Member States, five the Commission (one of which is 
the  EEA),  and  eight  target  both  Member  States  and  the  Commission.  The  remaining 
obligation refers to the Climate Change Committee to assist the Commission and cannot 
be  attributed  to  any  of  the  stakeholders  listed  above.  Before  the  introduction  of  the 
Governance Regulation, there were 54 obligations i in energy legislation (from 20 different 
pieces of legislation). According to the Fitness Check of 2016, this landscape of EU energy 
policy was characterised by a highly fragmented system  of planning and reporting, with 
numerous  co-existing  obligations,  each  designed  for  specific  aspects  of  the  EU  energy 
policy  acquis,  leading  to  inefficiencies  and  inconsistencies19.  The  Governance  Regulation 
did not intend to repeal/impact most of the pieces of legislation identified as relevant, but, 
rather, to streamline a large part of the planning, reporting and monitoring obligations in 
such legislation.  

Annex 7 summarises the obligations (both as part of the energy acquis and the MMR) that 
were integrated into the Governance Regulation and indicates the corresponding provisions 
of the Regulation. It also indicates whether the legal basis for the original obligations has 
since been amended.  

Correct identification of the legislation and related reporting obligations in the baseline is 
particularly important for the  effectiveness criterion (e.g. to assess any improvement in 
the  timeliness  and  quality  of  the  information  available)  and  the  efficiency  criterion  (to 
understand whether any streamlining and/or simplification of reporting has been achieved, 
leading to reduced costs and administrative burden). 

3.2.1  Integrated NECPs  

Before  the  Governance  Regulation  and  the  introduction  of  NECPs,  there  were  various 
separate planning and reporting mechanisms. These included National Renewable Energy 
Action Plans (NREAPs), introduced by the RED, which required Member States to outline 
strategies and measures to meet their 2020 renewable energy targets, and National Energy 
Efficiency Action Plans (NEEAPs), introduced by the EED, which required Member States to 
report  progress  towards  their  national  energy  efficiency  targets.  The  mechanism  for 
monitoring  GHGs,  introduced  by  the  MMR,  also  required  Member  States  to  report  GHG 
emissions. By introducing NECPs, the EU sought to integrate reporting on renewable energy 
and  energy  efficiency,  with  reporting  on  broader  objectives  encompassing  adaptation  to 
climate change (previously reported by most Member States in their national adaptation 
strategies20),  energy  security,  energy  markets, 
innovation  and 
competitiveness. These various reporting requirements followed different timelines, which 
did not help their alignment on targets, scenarios or progress reviews.   

research  and 

For example, there may have been instances where different plans (e.g. NREAPs, NEEAPs) 
were  developed  based  on  different  scenarios  and  with  different  assumptions  about 

19  Williams,  R.,  Veenstra,  E.,  Rademaekers,  K.,  Svatikova,  K.,  Baroni,  L.,  Fitness  Check  Evaluation  in  the  EU 
Energy  acquis  and  Impact Assessment of  Planning,  Reporting  and Monitoring for  the  Energy Union,  Trinomics 
B.V, 2016.  
20 As of 2018, 25 Member States had developed a national adaptation strategy.  

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population  and  economic  growth.  Nevertheless,  each  was  supposed  to  contribute  to  the 
ESD (reductions in GHG emissions in non-Emissions Trading Scheme (ETS) sectors), and 
to  2020  climate  targets  more  generally,  thereby  ensuring  a  minimum  degree  of 
consistency. The concept of ‘energy poverty’ was mostly related to the Electricity Directive. 
The Energy Efficiency First (EEF) principle was not included (not yet defined, nor required). 

On  the  planning  side,  there  was  no  iterative  process  (i.e.  the  submission  of  plans  by 
Member  States  to  the  European  Commission  was  not  followed  by  Commission 
recommendations to Member States). Nevertheless, the European Commission did assess 
plans and its assessments sometimes included recommendations on energy efficiency, or 
highlighted good practices, although Member States were not required to follow-up or act 
on these. A key initiative to achieve the 2020 energy efficiency targets was the creation of 
a dedicated Task Force in July 201821. In parallel, most of the bilateral exchanges between 
the  Commission  and  Member  States  related  to  the  assessment  of  the  transposition  of 
relevant  directives  and  to  notifications  of  their  various  provisions.  Most  of  this 
communication was not public. 

The concept of integrated NECPs containing information about the five dimensions of the 
Energy Union reflects each dimension’s role in a broader framework, where it contributes 
to common ‘umbrella’ objectives and targets and forms part of a common scenario.  

One potential drawback of the NECPs compared to the separate plans is that they may not 
offer the same level of detail for some dimensions. The requirements for each dimension 
set in the NECP template (Annex I to the Governance Regulation) reflect the main planning 
elements, but do not require comprehensive strategies for each element to be described. 
For  example,  NECP  section  3.2  requires  Member  States  to  report  ‘planned  policies, 
measures  and  programmes  to  achieve  the  indicative  national  energy  efficiency 
contributions for 2030 as well as other objectives’. This implicitly covers the main measures 
in all end-use sectors, as indicative national energy efficiency contributions relate to the 
whole  final  energy  consumption  (FEC).  However,  the  elements  listed  in  section  3.2 
correspond to reporting obligations in relation to energy efficiency (e.g. EED energy savings 
obligation or LTRSs). In practice, NECPs do not always set out sectoral measures and may 
not provide a clear view of whether the strategy on energy efficiency is comprehensive and 
well balanced. Previously, most NEEAPs presented measures per sector, with an additional 
part on cross-cutting measures. 

In the NECP template, energy poverty is included in the parts related to the energy market. 
However,  the  assessment  of  energy  poverty  (section  2.4.4)  is  also  relevant  to  other 
dimensions,  and  the  measures  to  tackle  energy  poverty  (section  3.4.4)  often  include  a 
combination of measures related to energy markets (e.g. social tariffs), energy efficiency 
(dedicated  renovation  programmes,  etc.)  and  renewable  energy  sources  (RES)  (e.g. 
schemes  to  ensure  that  energy-poor  households  benefit  from  on-site  solar  photovoltaic 
(PV)). Some measures can cut across various dimensions of the Energy Union (e.g. energy 
advice on choosing appropriate energy tariffs, as well as energy savings tips).  

The  Governance  Regulation  introduced  and  defined  the  EEF  principle,  which  prioritises 
energy efficiency measures over other ways of meeting energy demand. This principle is 
meant to contribute to ‘the interlinkages between the five dimensions of the Energy Union 
(Article  3(3)(a)).  Since  the  introduction  of  the  Governance  Regulation,  Member  States 
must take the EEF principle into account when developing and reporting national PaMs in 
their NECPs. References to the EEF principle are now included in most (if not all) related 
EU legislation, including the recast EED, with related provisions (Article 27) about energy 

21 ‘In order to better assess the growing energy consumption trend and identify a possible way forward, in July 
2018 the European Commission set up a Task Force on mobilising efforts to reach the EU energy efficiency targets 
for  2020’  (Report  from  the Commission  to  the  European  Parliament  and  the  Council,  2018  assessment  of  the 
progress  made  by  Member  States  towards  the  national  energy  efficiency  targets  for  2020  and  towards  the 
implementation of the Energy Efficiency Directive as required by Article 24(3) of the Energy Efficiency Directive 
2012/27/EU, 
https://eur-lex.europa.eu/legal-
COM(2019) 
content/EN/TXT/PDF/?uri=CELEX:52019DC0224). 

final, 

224 

3, 

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efficiency  on  the  supply-side,  including  requirements  for  national  regulatory  authorities 
and  the  Transmission  and  Distribution  System  Operators.  The  EEF  principle  of  the 
Governance Regulation relates only to demand-side measures. 

The process of drawing up NECPs (and NECP updates) includes iteration: Member States 
submit a draft, which is assessed by the Commission, leading to recommendations for each 
individual  Member  State,  which  then  leads  to  a  final  version.  The  Commission’s 
assessments  and  recommendations  are  public,  as  is  information  on  whether  and  how 
Member States have addressed the CSRs (NECP updates). This increases transparency. 

3.2.2  Long-term strategies  

The entry into force of the Governance Regulation marked a significant evolution from the 
framework  established  by  the  MMR.  Previously,  there  was  no  EU-wide  obligation  for 
Member States to prepare national LTSs on energy or on climate change mitigation and 
adaptation. The Paris Agreement, however, invited (but did not oblige) countries to prepare 
long-term  low  GHG  emission  development  strategies  (LT-LEDS).  The  Governance 
Regulation  enhanced  the  requirements  for  integrated  national  planning  and  reporting, 
explicitly incorporating long-term strategies for GHG emissions reduction and adaptation 
to climate change with those for energy. 

In mandating Member States to prepare and submit LTSs with a perspective of at least 30 
years,  the  Governance  Regulation  introduced  a  wider  forward-looking  vision.  These 
strategies should outline national objectives and visions for reducing GHG emissions and 
increasing  removals  towards  2050,  aligning  with  the  EU's  long-term  goal  of  achieving  a 
climate-neutral  economy  and  integrating  with  renewable  energy  and  energy  efficiency 
goals. 

3.2.3  Biennial Reporting (Articles 17 to 25 of the Governance Regulation) 

This section describes the evolution of key reporting obligations included in the Governance 
Regulation.   

3.2.3.1  Integrated national energy and climate progress reports (Article 17 of the 

Governance Regulation) 

Before the Governance Regulation, the EU’s 2020 climate and energy package set targets 
for  GHG  emission  reductions,  renewable  energy  and  energy  efficiency,  but  relied  on 
different instruments for monitoring progress in each area. For instance, the RED and the 
EED each imposed their own reporting requirements on Member States. 

The  MMR  consolidated  EU  climate  reporting  obligations  and  required  Member  States  to 
report GHG emissions and other relevant information, but did not integrate this reporting 
with progress on energy targets in a single framework. 

Prior  to  the  Governance  Regulation,  Member  States  were  required  to  submit  various 
national  plans  and  strategies  covering  renewable  energy,  energy  efficiency,  and  GHG 
emissions  reductions.  These  submissions  were  often  not  fully  coordinated  or  integrated, 
leading to potential overlaps, gaps, or inconsistencies in reporting. 

3.2.3.2  Integrated  reporting  on  GHG  PaMs  and  projections  (Article  18  of  the 

Governance Regulation) 

Before the Governance Regulation, the EU framework for reporting on GHG PaMs, as well 
as projections (under the MMR), provided a detailed and structured approach to climate 
reporting, but was less integrated with energy policy objectives. The Regulation enhanced 
this  framework  by  integrating  GHG  reporting  into  a  comprehensive  and  coordinated 
planning  and  reporting  process.  It  introduced  a  more  holistic  approach,  integrating 
reporting on GHG PaMs with the broader framework of the Energy Union’s objectives. Like 
the  MMR  (Article  13(3)  and  14(4)  MMR),  the  Governance  Regulation  (Article  18) 
emphasises transparency, requiring Member States to make their national GHG projections 
and  assessments  of  the  costs  and  effects  of  national  PaMs  available  to  the  public 
electronically.  

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3.2.3.3  Integrated  reporting  on  national  adaptation  actions,  financial  and 
technology  support  provided  to  developing  countries  and  auctioning 
revenues (Article 19 of the Governance Regulation) 

Before the Governance Regulation, reporting on national adaptation actions, financial and 
technological  support  to  developing  countries,  and  the  use  of  auctioning  revenues  took 
place under different frameworks and obligations at both EU and international level. The 
Regulation  streamlined  these  reporting  requirements  into  a  more  cohesive  framework, 
improving transparency, coordination, and the effectiveness of EU climate action efforts: 
  National  adaptation  actions  -  adaptation  reporting:  Before  the  Governance 
Regulation,  the  EU  Adaptation  Strategy  encouraged  Member  States  to  adopt 
national adaptation strategies and plans. From March 2015, the MMR also required 
Member States to report on national adaptation planning and strategies every four 
years and provided a brief list of report topics (e.g. flooding, sea level rise, extreme 
temperatures,  droughts,  and  other  extreme  weather  events).  In  comparison,  the 
Governance Regulation requires Member States to report on their national climate 
change  adaptation  and  planning  strategies  every  two  years  (from  2021)  and 
provides  more  detailed  instructions  on  the  information  that  should  be  reported 
(Annex VIII). Prior to the Regulation, reporting on adaptation measures was more 
fragmented and primarily shared through various networks and platforms, like the 
Climate-ADAPT platform, without a standardised reporting framework. 

  Financial  and  technology  support  to  developing  countries  -  international  climate 
finance  reporting:  EU  Member  States  have  long  been  committed  to  supporting 
developing  countries  in  their  climate  mitigation  and  adaptation  efforts,  including 
financial  and  technology  support.  This  commitment  aligns  with  international 
agreements, such as the UNFCCC and the Paris Agreement. Member States reported 
their climate finance contributions through biennial reports and strategies submitted 
to  the  UNFCCC,  but  under  the  MMR  (Article  16)  there  was  less  coordination  and 
guidance on this reporting at EU level.  

  Auctioning revenues - EU ETS and auctioning revenues: Directive 2003/87/EC (EU 
ETS)  provides  that  a  significant  portion  of  allowances  should  be  auctioned  by 
Member  States.  The  Directive  suggests  that  Member  States  use  that  revenue  to 
finance climate and energy-related projects, including activities related to reducing 
GHG  emissions,  adapting  to  climate  change,  and  providing  financial  and 
technological support to third countries. However, detailed and integrated reporting 
on the use of auctioning revenues at EU level was not explicitly outlined until the 
Governance Regulation. 

3.2.4  Annual reporting  

3.2.4.1  Annual reporting (Article 26 of the Governance Regulation) 

While  the  MMR  established  a  robust  system  for  annual  GHG  reporting,  the  Governance 
Regulation  enhanced  that  system  by  making  it  part  of  comprehensive  and  strategic 
planning  for  energy  and  climate  action.  The  Governance  Regulation’s  approach  not  only 
maintains the rigour and transparency  of  GHG  reporting, but aligns it  more  closely with 
the  EU's  broader  objectives  for  energy  and  climate,  fostering  a  more  coordinated  and 
ambitious response to climate change.  

  The  MMR  established  a  framework  for  systematic  monitoring,  reporting,  and 
verification (MRV) of GHG emissions, aiming to ensure accurate and consistent GHG 
data  across  the  EU.  It  required  Member  States  to  report  their  GHG  emissions 
annually, based on agreed methodologies and using standardised formats to ensure 
comparability of data. The MMR established annual GHG inventories where Member 
States were required to compile and submit annual inventories of GHG emissions, 
covering  all  sectors  of  the  economy.  Inventories  were  compiled  in  a  common 
reporting  framework,  with  detailed  guidelines  on  how  to  monitor  and  report 
emissions,  ensuring  a  high  level  of  transparency  and  accountability  in  the  EU's 

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climate reporting. The MMR included provisions for the verification of reported data 
to  ensure  its  accuracy  and  reliability.  It  also  set  out  procedures  for  addressing 
instances of non-compliance with reporting obligations. 

  The Governance Regulation built on the foundation laid by the MMR and introduced 
several  improvements  to  the  annual  GHG  reporting  process,  enhancing  its 
effectiveness  and  integration  with  broader  EU  climate  and  energy  governance. 
Changes  included  its  integration  with  NECPs,  requiring  Member  States  to  include 
their  GHG  reporting  with  their  broader  strategies  for  energy  and  climate.  This 
approach ensures that GHG reporting is considered in the context of overall national 
plans  for  achieving  energy  and  climate  targets,  creating  a  more  holistic  view  of 
progress and challenges.  

  By  consolidating  various  reporting  obligations  under  a  single  framework,  the 
Governance  Regulation  sought  to  reduce  the  administrative  burden  on  Member 
States  and  simplify  the  overall  process  of  monitoring  and  reporting,  including  on 
GHG emissions. This streamlined approach was expected to enhance the efficiency 
of  data  collection  and  analysis,  facilitating  more  timely  and  informed  decision-
making.  

  The Governance Regulation establishes a governance framework that supports the 
EU's commitment to achieving its 2030 climate and energy targets and its long-term 
objective  of  becoming  climate-neutral  by  2050.  The  integration  of  annual  GHG 
reporting  within  this  framework  enhances  accountability  and  supports  a  more 
ambitious approach to reducing emissions. 

3.2.4.2  Reporting on the 2020 targets (Article 27 of the Governance Regulation) 

Prior  to  the  Governance  Regulation,  NEEAPs  were  prepared  every  three  years  by  the 
Member States, in accordance with Article 24  of the EED.  The NEEAPs were  required to 
outline the significant energy efficiency measures implemented by the Member States and 
corresponding energy savings expected and/or achieved.  

Article 27 of the Governance Regulation introduced a requirement for each Member State 
to  report  to  the  European  Commission  on  the  achievement  of  its  2020  national  energy 
efficiency  targets,  including  information  about  the  sectoral  and  overall  shares  of  energy 
from renewable sources, measures taken to achieve the 2020 national renewable energy 
targets  (including  support  schemes,  Guarantees  of  Origin  (GoO),  simplification  of 
administrative procedures), and the share of energy from biofuels, bioliquids and biogas 
produced for transport. Union and national systems  on GHG  emissions and removals by 
sinks (Chapter 6) - (Article 37) 

On  national  and  Union  GHG  inventory  systems,  the  transition  from  the  MMR  to  the 
Governance Regulation involved a continuation of established practices and refinements to 
enhance the overall framework for GHG inventories in the EU. 

  Annual  Member  State  GHG  inventories:  Both  the  MMR  and  the  Governance 
Regulation require Member States to compile and submit annual inventories of GHG 
emissions.  These  inventories  must  cover  all  sectors  of  the  economy  and  use 
methodologies consistent with international standards, particularly those set by the 
Intergovernmental Panel on Climate Change (IPCC); 

  Union  inventory:  Under  both  regulations,  the  European  Commission  compiles  the 
Union  inventory  from  the  data  submitted  by  Member  States.  This  consolidated 
inventory  is  submitted  to  the  UNFCCC,  fulfilling  the  EU’s  international  reporting 
obligations. 

  Enhancements  introduced  by  the  Governance  Regulation:  While  maintaining  the 
core  inventory  reporting  obligations,  the  Governance  Regulation  reinforced  the 
effectiveness and integration of the inventory systems within the broader context of 
EU  climate  and  energy  governance.  It  integrates  GHG  inventory  reporting  more 
explicitly with the broader strategic framework of the NECPs, ensuring that it is not 
only a compliance tool, but central to assessing progress towards targets, thereby 

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enhancing  the  strategic  use  of  inventory  data  for  climate  policy  planning  and 
implementation.  

By consolidating the reporting requirements, the Governance Regulation streamlines the 
administrative processes associated with inventory reporting. This consolidation is intended 
to  reduce  the  reporting  burden  on  Member  States  and  improve  the  efficiency  of  data 
collection, verification, and submission processes. 

The MMR emphasised the importance of quality assurance (QA) and quality control (QC) 
procedures and the Governance Regulation continues to stress the need for robust QA/QC 
practices.  It  encourages  Member  States  to  develop  and  refine  their  inventory  systems, 
ensuring that GHG data are accurate, consistent and transparent. 

Inventory review (Article 38 of the Governance Regulation) 

Before the Governance Regulation, the framework for the review of GHG inventories in the 
European  Union  was  established  under  the  MMR,  which  set  out  the  procedures  for  the 
review of GHG inventories by Member States, aiming to ensure the accuracy, consistency, 
and transparency of GHG data reported to the European Commission and, ultimately, to 
the UNFCCC. 

  MMR  provisions  for  reviews  of  GHG  inventories:  Reviews  were  carried  out  at  EU 
level,  involving  expert  review  teams  to  assess  the  completeness,  accuracy  and 
adherence to reporting guidelines of the inventories submitted by Member States. 
  The Governance Regulation enhanced the inventory review framework established 
by the MMR. Beyond the explicit requirements under Article 38, it sets out a broader 
review of national energy and climate reporting, including NECPs and NECPRs. This 
approach  ensures  that  the  review  of  GHG  inventories  is  not  only  about  verifying 
data, but assessing progress towards broader climate and energy targets. 

  Enhanced  review  procedures:  While  maintaining  the  rigorous  review  processes 
established by the MMR, the Governance Regulation emphasises the importance of 
transparency, accuracy, and completeness in GHG inventories. It establishes clearer 
roles and responsibilities for the European Commission and Member States in the 
review process. It also provides a more structured framework for the Commission 
to assess, report, and follow up the findings of inventory reviews, including issuing 
recommendations for improvements. 

The  Governance  Regulation  acknowledges  the  importance  of  capacity-building  and 
technical support for Member States to improve their GHG inventory systems and increased 
the  focus  on  this  aspect  accordingly.  It  encourages  sharing  of  best  practices  and  the 
provision of technical assistance to Member States, particularly those facing challenges in 
meeting the reporting and review requirements. 

3.2.4.3  Union  and  national  systems  for  PaMs  and  projections  (Article  39  of  the 

Governance Regulation) 

Article 12 of the MMR and Article 39 of the Governance Regulation both address aspects of 
systems for reporting on PaMs and projections related to GHG emissions within the EU: 

  Reporting on PaMs: Both articles require Member States to establish and maintain 
national systems for reporting on their national PaMs to reduce GHG emissions. This 
includes implemented and planned measures, reflecting a continuous commitment 
to documenting and communicating efforts to mitigate climate change; 

  Projections  of  GHG  emissions:  Both  articles  mandate  the  establishment  and 
maintenance  of  national  systems  for  reporting  projections  of  GHG  emissions  and 
removals.  These  projections  are  essential  for  assessing  future  trends  in  GHG 
emissions  and  the  potential  impact  of  PaMs  on  achieving  emissions  reduction 
targets; 

  Integration with NECPs: One of the major differences introduced by the Governance 
Regulation is the implicit integration of reporting on PaMs and projections within the 
framework of NECPs. Although this is not explicitly mentioned in Article 39 of the 

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Governance  Regulation,  it  ensures  that  national  systems  are  aligned  with  the 
broader  strategic  planning  and  implementation  process  outlined  in  the  NECPs, 
enhancing coherence and synergy among various climate and energy policies. The 
MMR, while comprehensive, did not embed PaMs and projections reporting within a 
similarly integrated planning framework.

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4 

HOW  HAS  THE  SITUATION  EVOLVED  OVER  THE  EVALUATION 
PERIOD? 

This section describes how the situation evolved in the period leading up to the adoption 
of the Governance Regulation and in the years following its adoption and implementation 
by  the  Member  States.  Several  international  policy  developments,  internal  EU  policy 
developments, and external geopolitical and other developments have interacted with and 
affected the implementation of the Governance Regulation. These are described below.  

4.1 

 Policy developments 

This section presents the key policy developments since the adoption of the Governance 
Regulation.  

4.1.1  International policy developments 

At international level, key policy developments include: 

  The  enhanced  transparency  framework  established  by  the  Paris  Agreement 
(November 2016) to track the progress of individual Parties in the implementation 
of their nationally determined contributions (NDCs), provide data to support global 
stocktakes, and assess progress towards the long-term goals; 

  Parties under the Paris Agreement (Article 7(1)) also committed to the Global Goal 
on  Adaptation,  which  aims  to  enhance  global  adaptive  capacity  and  strengthen 
resilience and reduce vulnerability to climate change. During the Conference of the 
Parties  of  the  UNFCCC  (COP28)  (November  2023),  a  Global  Climate  Resilience 
Framework was proposed, highlighting the key areas requiring adaptation efforts in 
all countries, including food security, water management and public health22; 
  The 2021 Glasgow Climate Pact, which seeks to raise mitigation ambition through 
coal  phase-down,  termination  of  fossil  fuels  subsidies  and  the  reduction  of  non-
carbon dioxide (CO2) GHG emissions;  

  The Kunming-Montreal Global Biodiversity Framework (adopted in December 2022) 
highlights that the climate and biodiversity crises are interdependent. It establishes 
targets to tackle both crises in a coherent manner – including in terms of financial 
objectives;  

  Global  Pledge  on  Renewables  and  Energy  Efficiency  (December  2023)  sets  global 
targets  to  triple  the  global  installed  capacity  of  renewable  energy  and  double  the 
global rate of energy efficiency improvements by 2030. 

4.1.2  EU policy developments 

The European Green Deal (approved in 2020) and its subsequent legislation, such as the 
European Climate Law (April 2021) and the Fit For 55 package (July 2021) have established 
and operationalised the EU 2030 and 2050 climate objectives. The European Green Deal 
promote  further  coherence  between  policies,  notably  energy,  climate,  and  other 
environmental policies (biodiversity, pollution, circular economy), including through the ‘do 
no  significant  harm’  (DNSH)  principle.  The  2021  EU  Adaptation  Strategy,  as  part  of  the 
European Green Deal and under the European Climate Law, pursues more of a whole-of-
government approach than its predecessors, aiming to make adaptation 'smarter, faster 
and more systemic', while also minimising the risks to EU countries from climate impacts 
beyond European borders. 

Building on Fit for 55, the REPowerEU Plan is among the EU responses to the energy crisis 
provoked  by  Russia’s  war  of  aggression  against  Ukraine.  It  includes  a  set  of  actions  to 
reduce  energy  demand,  reduce  dependence  on  Russian  fossil  fuels  and  accelerate 

22 Hussein F et al (2024): Understanding the Paris Agreement’s “Global Goal on Adaptation”, Article for World 
Resources 
https://www.wri.org/insights/global-goal-on-adaptation-
explained#:~:text=The%20Global%20Goal%20on%20Adaptation%20is%20a%20collective%20commitment%
20under,in%202015%2C%20the%20GGA%20is 

Institute, 

available 

at: 

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investments  in  renewable  energy,  while  achieving  higher  energy  efficiency.  These 
instruments are underpinned by interventions mitigating adverse economic impacts owing 
to the transition to climate neutrality and the COVID-19 crisis, such as the JTF and RRF. 
Established  during  the  COVID-19  pandemic,  the  RRF  supports  Member  States  to  adopt 
reforms and investments to prompt the recovery of their economies after the pandemic, 
and  to  make  their  economies,  energy  systems  and  societies  more  sustainable,  resilient, 
and  prepared  for  the  green  and  digital  transitions,  in  line  with  the  EU’s  priorities  and 
REPowerEU  Plan.  The  RRF  should  be  consistent  with  the  relevant  country-specific 
challenges  identified  in  the  context  of  the  European  Semester  process  of  the  economic 
governance framework and with information in Member States’ NECPs. 

The following sub-sections describe the European Green Deal, European Climate Law and 
Fit for 55 package in more detail.  

4.1.2.1  European Green Deal 

The European Green Deal23 is a comprehensive and ambitious set of policy initiatives by 
the European Commission that aims to make the EU climate neutral by 2050. It aims to 
transform the economy of the Union such that it is more sustainable, resource-efficient, 
and competitive. In general, the Governance Regulation aims to bolster energy and climate 
policy coordination, oversight, and long-term roadmapping towards the implementation of 
the Union’s  energy and climate targets. Its inclusion and integration  of multiple aspects 
reflects attempts to better integrate EU climate and energy legislation, as well as to align 
planning and targets with the Paris Agreement. This is clearly conducive to the goals of the 
European Green Deal.  

The  European  Green  Deal  has  been  criticised  for  not  being  ambitious  enough  in  certain 
aspects (e.g. approach  to  reducing fossil fuel use24) and  for being overly ambitious and 
risking  the  competitiveness  of  Member  States  and  the  EU  collectively.  The  related 
comprehensive and intense legislative process changed the context of the 10-year cycle 
initially planned by the Governance Regulation. 

The  ambition  of  the  European  Green  Deal  can  be  expressed  as  ‘Climate  change  and 
environmental degradation are an existential threat to Europe and the world. To overcome 
these challenges, the European Green Deal will transform the EU into a modern, resource-
efficient, and competitive economy, ensuring: 
  No net emissions of GHGs by 2050; 
  Economic growth decoupled from resource use; and 
  No person and no place left behind’25. 

4.1.2.2  European Climate Law 

The European Climate Law26 entered into force in 2021 and enshrines in law the goal of 
achieving climate-neutrality in the EU by 2050. It also codifies the updated 2030 target, 
whereby the EU is legally bound to reduce its net GHG emissions by at least 55 % compared 
to  1990  levels.  The  relevant  Union  institutions  and  all  Member  States  are  to  take  the 
necessary  measures  at  Union  and  national  level,  respectively,  to  enable  the  collective 
achievement  of  the  climate-neutrality  objective  (Article  2(1))  and  ensure  continuous 
progress  in  enhancing  adaptive  capacity,  strengthening  resilience,  and  reducing 
vulnerability to climate change in accordance with Article 7 of the Paris Agreement (Article 

23  European  Commission,  The  European  Green  Deal,  n.d.,  https://commission.europa.eu/strategy-and-
policy/priorities-2019-2024/european-green-deal_en  
24 European Environmental Bureau (EEB),  EU plans multi-billion euro ‘green recovery’ but falls short in crucial 
areas, 2020, https://eeb.org/eu-plans-multi-billion-euro-green-recovery-but-falls-short-in-crucial-areas-1/ 
25  European  Commission,  The  European  Green  Deal,  2023,  https://commission.europa.eu/strategy-and-
policy/priorities-2019-2024/european-green-deal_en.  
26 Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 establishing the 
framework  for  achieving climate  neutrality  and  amending Regulations  (EC)  No 401/2009  and  (EU) 2018/1999 
(‘European Climate Law’), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R1119  

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5(1)). This includes working together with all groups and through international cooperation 
to  support  adaptation  efforts,  particularly  for  the  most  vulnerable.  National  adaptation 
plans, the EU Adaptation Strategy (Article 5(2)), and information on support to developing 
countries are all reporting requirements. 

The  European  Climate  Law’s  system  of  assessing  progress  towards  achieving  climate-
neutrality and adaptation objectives, as well as the consistency of measures, builds on and 
is  consistent  with  the  governance  framework  laid  down  in  the  Governance  Regulation. 
Instead  of  introducing  additional  separate  reports  by  Member  States  on  their  progress 
towards  European  Climate  Law  objectives,  the  relevant  provisions  of  the  Governance 
Regulation  reflected  that  information  submitted  by  Member  States  would  include  more 
information on progress towards European Climate Law objectives.  

Many  elements  contained  within  the  European  Climate  Law  (e.g.  tracking  progress)  are 
built on the governance process.  

4.1.2.3  Fit for 55 package 

Fit for 55 is the package of new and revised energy and climate-relevant legislation needed 
to achieve the EU’s updated and more ambitious target for emissions reductions by 2030. 
Previously, the target for the EU was at least 40 % reduction in gross GHG emissions by 
2030 compared to 1990 levels; the new target increases this to at least 55 % net  GHG 
reduction by 2030. The Fit for 55 package was officially announced in July 2021 and most 
of the elements were adopted in 2023 as part of the European Green Deal27,28. To meet 
the  increased  net  emissions  reduction,  Fit  for  55  deploys  a  mix  of  targets,  pricing, 
standards, and support measures (see Figure 3). 

27 Council of the EU, ‘Fit for 55': Council adopts key pieces of legislation delivering on 2030 climate targets, Press 
release,  25  April  2023,  https://www.consilium.europa.eu/en/press/press-releases/2023/04/25/Fit  for  55Fit  for 
55-council-adopts-key-pieces-of-legislation-delivering-on-2030-climate-targets/  
28 The Dispatch, ‘Two Final Elements of Fit for 55 adopted’, CDE News, 3 November 2023, https://cde.news/two-
final-elements-of-Fit for 55Fit for 55-adopted/ 

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Figure 3.   Policy mix under the Fit For 55 package 

Source: ICF, based on COM(2021) 550 final29.  

The Fit for 55 package attempts to integrate climate and energy elements in a joined-up 
legal  framework,  driven  by  the  overriding  target  of  the  55 %  emissions  reduction.  The 
package is extensive, containing several policies: 

  Revision of the EU ETS: Increasing the overall ambition of emissions reductions 
by 2030 in the sectors covered by the EU ETS to 62 % compared to 2005 levels. 
The EU ETS currently covers industries responsible for 40 % of EU GHG emissions, 
as well as aircraft operators within the EU. Free emission allowances for the aviation 
sector will be phased out, with full auctioning implemented from 2026. For the first 
time, the EU ETS includes emissions from shipping within its scope. Under the 2023 
revisions of the ETS Directive, a new, separate emissions trading system (ETS 2) 
was established, covering buildings, road transport and additional sectors (mainly 
small industry not covered by the EU ETS). The ETS 2 emissions reduction target is 
to reduce emissions by 42 % by 2030, compared to 2005 levels. The Social Climate 
Fund will become operational in 2027 and will be funded by the ETS 2, to the value 
of  EUR  65  billion.  It  will  be  used  by  Member  States  to  finance  measures  and 
investments  to  support  vulnerable  households,  micro-enterprises,  and  transport 
users.  

  Stricter  GHG  limits  for  sectors  not  covered  by  EU  ETS  1  before  its 
amendment: The co-legislators have adopted revised binding national targets to 
reduce GHG emissions for sectors covered by the ESR, accounting for nearly 60 % 
of EU GHG emissions. These sectors include transport (excluding CO2 from aviation), 
buildings, agriculture, waste, and small industries. Neither the ETS nor ESR cover 

29 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions, 'Fit for 55': delivering the EU's 2030 Climate Target on the 
way 
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52021DC0550&from=EN  

neutrality, 

climate 

to 

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LULUCF. The significant revision to the ESR, which entered into force in May 2023, 
sets  an  EU-wide  GHG  emission  reduction  target  of  40 %  (raised  from  29 %) 
compared  to  2005  levels.  As  a  collective  contribution,  this  is  translated  into 
individual Member State targets, ranging from 10 % in Bulgaria to 50 % in higher 
income  Member  States  such  as  Finland,  Sweden,  Luxembourg,  Germany  and 
Denmark.  

  Updated LULUCF Regulation: The update stipulates a target of increasing land-
based net carbon removals in the Union by 42 million tonnes of CO2-equivalent by 
2030. For the period from 2026-2030, each Member State will, for the first time, 
have  a  binding  national  target  amounting  to  310 Mt  by  2030.  Moving  from 
accounted to reported values in the second compliance period will bring the LULUCF 
Regulation  closer  in  line  with  the  national  GHG  inventories  submitted  under  the 
Governance  Regulation.  Additionally,  Member  States  will  move  towards  higher 
accuracy  in  their  reporting,  based  on  remote  (satellite)  and  in-field  data  and  are 
encouraged  to  provide  this  information  in  their  NECPs.  The  LULUCF  Regulation 
provides for Member State flexibility to help them reach their targets.  

  Stricter EU caps on CO2 emissions from new cars and vans: The revised law 
will  require  new  cars  to  be  zero-emission  from  2035.  It  also  sets  CO2  emission 
reduction targets for 2030 for new cars and vans. 

  Updated renewable energy targets: The recast RED states that at least 42.5 % 
(aiming for 45 %) of EU energy consumption must be from RES by 2030, an increase 
from the old target of 32 %. It also reinforces the sustainability criteria for biomass 
used  for  energy,  strengthens  the  links  between  bioenergy  and  LULUCF  (including 
provisions  related  to  NECPs)  and  introduces  the  cascading  principle  to  Member 
States’  financial  support  schemes  for  bioenergy.  The  purpose  is  to  ensure  that 
bioenergy  (which  still  represents  almost  60 %  of  all  renewables)  is  sourced 
sustainably and is not inconsistent with achieving LULUCF targets.  

  Carbon Border Adjustment Mechanism (CBAM): CBAM is a policy tool designed 
to  encourage  non-EU  countries  wishing  to  import  goods  to  the  EU  to  reduce  the 
emissions in their manufacturing processes. CBAM targets industries that produce 
high  carbon  emissions,  aiming  to  reduce  carbon  leakage,  where  carbon-intense 
production simply moves to countries with less strict climate policy and legislation. 
The transitional phase of the CBAM started on 1 October 2023 and will run to 31 
December  2025,  with  a  first  reporting  period  for  importers  ending  on  31  January 
2024.  During  this  period,  EU  importers  will  have  to  comply  with  reporting 
requirements  but  will  not  need  to  purchase  CBAM  certificates.  The  main  policy 
requirements will commence on 1 January 2026.  

  Sustainable  fuels:  Various  policies  related  to  transitioning  to  sustainable  fuels 
have been adopted as part of the Fit for 55 package bey(ond the revised RED). For 
example,  a  policy  called  ReFuelEU  Aviation  targets  the  aviation  sector,  while  the 
FuelEU maritime initiative aims to reduce the GHG intensity of the energy used on 
ships by 80 % by 2050. 

  Gas  and  Hydrogen  Package:  Following  a  review  of  the  EU  gas  market,  this 
package  envisions  gradual  replacement  of  natural  gas  with  renewable  and  low-
carbon gases, including hydrogen. Accompanying policies help to create a regulatory 
infrastructure  (production,  distribution, 
framework 
utilisation), including energy infrastructure investments and state aid rules, as well 
as legislative targets for renewable hydrogen for the industry and transport sector. 
Two  delegated  acts  on  renewable  hydrogen  production  were  approved  in  June 
202330,  the  first  defining  the  conditions  under  which  hydrogen,  hydrogen-based 

for  dedicated  hydrogen 

https://energy.ec.europa.eu/news/renewable-hydrogen-production-new-rules-formally-adopted-2023-06-

30 
20_en 

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fuels, or other energy carriers can be considered renewable fuels of non-biological 
origin (RFNBOs), and the second providing a methodology for calculating life-cycle 
GHG emissions for RFNBOs.  

  Energy Efficiency: As part of the package, the EED was revised, committing the 
EU to reducing FEC at EU level by 11.7 % in 2030 compared to projections originally 
made in 2020 (after a second increase in ambition through RePowerEU). Together 
with the EED, the revised Directive 2010/31/EU (Energy Performance of Buildings 
Directive,  EPBD)  promotes  policies  to  achieve  a  highly  energy  efficient  and 
decarbonised building stock by 2050,  create a  stable  environment for  investment 
decisions, and enable consumers and businesses to make more informed choices to 
save energy and money. 

  Methane  Regulation:  The  regulation  around  the  potent  GHG  methane  obliges 
fossil  fuel  industries  to  adequately  measure,  report  and  verify  their  methane 
emissions and take action to reduce them. It aims to help the EU to achieve the aim 
set out in the Global Methane Pledge of reducing methane emissions  by 30 % by 
2030. 

The global profile of the Fit for 55 package aims to impact GHG emissions outside of the 
EU. For instance, the EU ETS involves activities with Norway, Iceland and Liechtenstein, 
and has a link to Switzerland. Norway and Iceland are also within scope of the ESR. As the 
Governance  Regulation  focuses  heavily  on  Member  States’  progress  reporting  towards 
targets, the many and  varied targets  set by Fit for 55 will be tracked using information 
from stipulations within the Governance Regulation. Member States must update their final 
NECPs by June 2024 (after submitting a draft NECP update by the end of June 2023), with 
the Fit for 55 package of laws likely resulting in extensive revisions to the final NECPs by 
Member States. 

Two  of  the  final  pillars  of  the  Fit  for  55  legislative  package,  the  revised  RED  and  the 
ReFuelEU Aviation Regulation, were adopted in October 2023, giving the EU legally binding 
climate targets covering all key sectors of the economy. The Commission reports that the 
final legislative package is expected to reduce EU net GHG emissions by 57 % by 203031.  

The intense period of discussing the legislative changes – and their implications for Member 
State’  planning  –  significantly  impacted  the  first  10-year  cycle  of  the  Governance 
Regulation.  The  new  versions  of  legislation  started  to  be  discussed  while  the  previous 
versions (from the ‘Clean Energy for all Europeans’ package32) were still being transposed, 
and  their  adoption  happened  at  the  same  time  or  after  Member  States  had  to  draft  the 
updates to their NECPs. 

4.2  Other developments (including changing geopolitical priorities) 

4.2.1  COVID-19 and NextGenerationEU 

The  unprecedented  COVID-19  pandemic,  successive  lockdowns  and  other  constraints 
considerably impacted the context for implementing the plans of the first 10-year cycle of 
the Governance Regulation. It transformed short-term priorities, induced sharp reductions 
in  energy  consumption  and  GHG  emissions,  and  prompted  other  changes,  such  as  an 
acceleration in digitalisation. 

Following the COVID-19 pandemic, the NextGenerationEU instrument was adopted to aid 
economic recovery. It will operate from 2021 until 2026. An integral part of this EUR 800 

2030 

31 European Commission, ‘Commission welcomes completion of key ‘Fit for 55’ legislation, putting EU on track to 
exceede 
2023, 
targets’, 
https://ec.europa.eu/commission/presscorner/detail/en/IP_23_4754 
32  European  Commission,  Clean  energy  for  all  Europeans,  2019,  https://op.europa.eu/en/publication-detail/-
/publication/b4e46873-7528-11e9-9f05-01aa75ed71a1/language-
en?WT.mc_id=Searchresult&WT.ria_c=null&WT.ria_f=3608&WT.ria_ev=search 

release, 

October 

Press 

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billion fund33 is the belief that the economic recovery provides an opportunity to ensure 
that  the  EU  recovers  to  be  greener  and  more  resilient  than  before.  ‘Green  transition’  is 
listed first among the six pillars setting the scope of the RRF (Article 3 of Regulation (EU) 
2021/241 (RRF Regulation))34. Beyond a general requirement to contribute to the green 
transition pillar, each Member State must dedicate at least 37 % of its national RRP’s total 
allocation to measures contributing to climate objectives35. Article 4 of the RRF Regulation 
stipulates that it should contribute to achieving the Union’s 2030 climate targets and the 
objective  of  EU  climate  neutrality  by  2050,  explicitly  referring  to  the  Governance 
Regulation.  This  is  transcribed  in  Article  17  of  the  RRF  Regulation,  which  requires  that 
national RRPs shall be  consistent with the information included ‘in their National Energy 
and Climate Plans and updates thereof under Regulation (EU) 2018/1999’. The funds are 
awarded  to  Member  States  in  line  with  their  national  RRPs,  with  a  very  wide  range  of 
projects (e.g. digitisation of public administration, building creches). Many projects support 
the green transition, for example electrifying railways or setting up national government 
funds to improve energy efficiency in residential homes36. 

National  RRPs  contribute  to  the  implementation  of  EU  climate  and  energy  policies.  The 
exceptional  funding  available  from  the  RRF  is  intended  to  encourage  Member  States  to 
become more ambitious with their green policies, in view of the increased EU climate and 
energy  ambitions  with  the  European  Green  Deal.  It  seeks  to  enable  Member  States  to 
increase significantly the funding of existing policies (e.g. Italy’s Superbonus for building 
renovation)  or  develop  new  schemes  with  specific  objectives  (e.g.  funding  for  local 
renovation  or urban regeneration programmes targeting deprived areas in Romania and 
Spain).  

This boost in Member States’ energy and climate measures may significantly impact the 
initial investment assumptions and planned PaMs presented in the NECPs submitted at the 
end of 2019. Not only should the new measures supported by the RRF be reported as part 
of the biennial reporting of PaMs pursuant to the Governance Regulation, they should also 
be reflected in the updated NECPs to be prepared in 2023-2024. Additionally, the measures 
introduced  in  Member  States’  RRPs  will  have  a  material  impact  on  their  GHG  emissions 
projections,  which  must  be  reported  to  the  EU  under  the  Governance  Regulation,  even 
though  changes  from  large  infrastructural  projects  may  only  materialise  outside  the 
timeframe of the existing NECPs. The reverse is also true, as the existing NECPs played an 
important  role  in  identifying  the  areas  where  this  extra  investment  money  should  be 
allocated. 

4.2.2  Russia’s  war  of  aggression  against  Ukraine,  the  energy  crisis  and 

REPowerEU 

Following the outbreak of Russia’s war of aggression against Ukraine in 2022, the European 
Commission proposed to end EU reliance on Russian fossil fuels well before 2030. The plan, 
REPowerEU 37, aims to increase energy security following disruptions to Russia’s gas supply. 
REPowerEU includes a set of actions to diversify the EU’s energy supplies and encourage 
the uptake of green energy, such as accelerating deployment of natural gas alternatives 
(e.g. sustainable biomethane, renewable and fossil-free hydrogen) and renewable sources 
(e.g. solar PV, offshore wind, as well as energy savings and energy efficiency.   

33 European Union, NextGenerationEU, 2023, https://next-generation-eu.europa.eu/index_en  
34 http://data.europa.eu/eli/reg/2021/241/oj 
35  European  Commission,  Green  transition,  2023,  https://ec.europa.eu/economy_finance/recovery-and-
resilience-scoreboard/green.html 
36 European Union, Recovery and Resilience Facility - Discover what's happening in each Member State, 2023,  
https://next-generation-eu.europa.eu/recovery-and-resilience-facility_en#paragraph_116 
37  European  Commission,  REPowerEU  –  Affordable,  secure,  and  sustainable  energy  for  Europe,  2023, 
https://commission.europa.eu/strategy-and-policy/priorities-2019-2024/european-green-deal/repowereu-
affordable-secure-and-sustainable-energy-europe_en.  

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An  urgent  aspect  of  REPowerEU  was  to  reduce  gas  usage  by  15 %  in  the  EU  between 
August 2022 and March 2023. It also proposed to increase the newly proposed renewable 
energy  targets  for  the  RED  from  40 %  to  45 %.  The  energy  efficiency  target  was  also 
increased to 11.7 % (from 9 %) reduction of FEC between 2020 and 2030. The proposal 
included many targets related to scaling-up the use of solar energy and biomethane, as 
well as improving the EU’s ability to utilise hydrogen and the deployment of heat pumps.  

The RRF Regulation was amended in 2022 to reflect the objectives of REPowerEU. Member 
States could revise their plans to add REPowerEU chapters and access additional funding 
opportunities  to  achieve    REPowerEU  objectives.  The  RRF’s  REPowerEU  chapter  includes 
reforms and investments that contribute effectively to energy security, diversification  of 
the Union’s energy supply, an increase in the uptake of renewables and energy efficiency, 
an  increase  of  energy  storage  capacities,  or  the  necessary  reduction  of  dependence  on 
fossil fuels before 2030. Reforms to be delivered through the RRF’s additional REPowerEU 
chapters may include an accelerated permitting regime for net-zero projects.  

Progress on REPowerEU will be reported through (among others) the State of the Energy 
Union Report and Climate Action Progress Report, published by the Commission as per the 
Governance Regulation. The Commission has published guidance on how Member States 
should reflect REPowerEU in their NECPs, e.g. they are required to report on their energy 
policies related to energy security.  

The  energy  crisis  has  had  several  impacts  that  clearly  interact  with  the  Governance 
Regulation’s objectives: 

  How energy data are monitored and reported by Member States and shared at EU 
level  (e.g.  need  to  know  developments  in  gas  storage  and  consumption  with  the 
shortest time lag possible); 

  Stronger coordination and cooperation among Member States on gas supply (e.g. 

joint purchase); 

  Immediate  action  plans  to  save  gas  in  the  short-term  that  may  complement  or 
interfere with the longer-term planning set out in the Governance Regulation. 

4.2.3  EU strategic autonomy: the Critical Raw Materials Act  

The  EU  aims  to  investigate  how  diversifying  its  supply  chains  can  mitigate  the  risk  to 
achieving  its  net  zero  ambitions,  especially  given  its  reliance  on  externally  produced 
technologies to achieve many of its  climate goals. The 2023 State  of  the Union address 
emphasised  leading  on  new  technologies38,  including  the  introduction  of  the  new  Wind 
Power package, which aims to significantly accelerate internal investment in offshore wind, 
as well as ocean energies39. 

A significant percentage (22 % in 2021) of the EU’s total GHG emissions stem from the 
road transport sector, with a swift move to zero-emission mobility seen as fundamental to 
achieving  EU  policy  goals.  However,  the  EU  currently  relies  on  importing  much  of  the 
necessary battery capacity.  

While the EU builds its own renewables market, it will be a challenge not to rely on outside 
resources,  increasing  exogenous  risk.  Many  renewable  technologies  require  rare  earth 
metals  for  their  production.  For  example,  the  magnets  used  in  many  wind  power 
technologies  require  elements  such  as  neodymium,  praseodymium,  terbium,  and 
dysprosium 40. To mitigate this, the European Commission has proposed a set of actions to 
ensure  access  to  critical  raw  materials  and  end  reliance  on  imports  from  ‘quasi-

38 European Commission, State of the Union, 2023, https://state-of-the-union.ec.europa.eu/index_en  
39 European Commission, EU wind energy, 2023, https://energy.ec.europa.eu/topics/renewable-energy/eu-wind-
energy_en  
40 Alves Dias, P., Bobba, S., Carrara, S. and Plazzotta, B., ‘The Role of Rare Earth Elements in Wind Energy and 
Electric Mobility’, Joint Research Centre (JRC) Science for Policy Report, European Commission, 2020. 

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monopolistic third-country suppliers’. In addition to providing an up-to-date list of critical 
raw materials, the Critical Raw Materials Act sets several benchmarks for domestic capacity 
along the strategic raw material supply chain in order to diversify EU supply by 2030:  

  At least 10 % of the EU's annual consumption for extraction; 
  At least 40 % of the EU's annual consumption for processing; 
  At least 15 % of the EU's annual consumption for recycling;  
  Not  more  than  65 %  of  the  Union's  annual  consumption  of  each  strategic  raw 

material at any relevant stage of processing from a single third country. 

Proposed at the same time and now provisionally agreed41, the NZIA sets the benchmark 
for  domestic  manufacturing  capacity  of  strategic  net-zero  technologies  to  meet  at  least 
40 % of the EU’s annual deployment needs by 2030. These strategic technologies include: 

  Solar PV and solar thermal technologies;   
  Onshore and offshore renewable technologies;   
  Battery/storage technologies;   
  Heat pumps and geothermal energy technologies;   
  Electrolysers and fuel cells;   
  Sustainable biogas/biomethane technologies;   
  Carbon capture and storage (CCS) technologies;    
  Grid technologies. 

Both  the  Critical  Raw  Materials  Act  and  NZIA  target  economic  changes  in  the  plan  to 
achieve net zero, which increase the EU’s strategic autonomy. This situation may call for 
reinforced coordination and cooperation among Member States to avoid shortages of key 
resources for their energy transition.  

41 Council of the EU, ‘Net-Zero Industry Act: Council and Parliament strike a deal to boost EU’s green industry’, 
Press  release,  6  February  2024,  https://www.consilium.europa.eu/en/press/press-releases/2024/02/06/net-
zero-industry-act-council-and-parliament-strike-a-deal-to-boost-eu-s-green-industry/  

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5 

FINDINGS  OF  THE  EVALUATION  ANSWERING  ALL  THE 
EVALUATION QUESTIONS  

This section presents the main findings of the evaluation and the answer to each evaluation 
question (EQ), as described in the Evaluation Framework (Annex V).  

5.1  To what extent was the intervention successful and why? 

This section presents the findings  on the  effectiveness (EQ1-EQ6),  efficiency (EQ7-EQ9) 
and  coherence  (EQ10-EQ11)  of  the  Governance  Regulation.  It  is  based  on  synthesis, 
analysis  and  triangulation  of  information  from  the  various  data  collection  tasks  (desk 
research,  surveys,  interviews,  CfE,  and  stakeholder  event).  Results  for  each  EQ  are 
presented in the following sub-sections. 

5.1.1  Effectiveness 

Quality of information 

The Governance Regulation has improved the quality of planning and reporting somewhat, 
but there remains room for improvement. More specifically, the evaluation finds that: 

  Individual Member States have taken varying approaches to reporting information 

in their NECPs; 

  On the quality of the information included in LTSs, there is improved coverage of 

the five dimensions prelisted in Article 15(4) of the Governance Regulation; 

  On  the  quality  of  reported  information  for  the  biennial  progress  reports  and  their 
follow  up,  the  enforcement  of  Article  17(2)(b)  proved  effective  only  to  a  limited 
extent, with significant data gaps remaining;  

  On the integrated planning and reporting on GHG PaMs and projections (Article 18), 
although the number of PaMs has increased over time, the completeness of reported 
information (particularly quantitative information) has deteriorated. The quality of 
information  on  projections  of  anthropogenic  GHG  emissions  by  sources  and 
removals by sinks increased from 2017 to 2021;  

  On reporting on adaptation (Article 19), monitoring and evaluation frameworks for 
adaptation  goals  are  either  recent  or  in  development  in  the  Member  States,  and 
operate  under  national  adaptation  strategies  or  plans.  They  rarely  consider 
synergies with the Energy Union dimensions, with only 13 Member States reporting 
clear progress on the implementation of actions for each adaptation goal;  

  On integrated reporting on renewable energy (Article 20), only limited information 
was  received  from  stakeholders.  This  information  was  not  easily  comparable  and 
robust conclusions could not be drawn;  

  On  integrated  reporting  on  energy  efficiency  (Article  21),  namely,  the  exemplary 
role  of  public  bodies’  buildings  (Article  5  EED),  compared  to  the  annual  reports 
submitted  in  2022,  information  is  lacking  in  the  reports  submitted  in  2023.  Four 
Member  States  (Hungary,  Latvia,  Portugal,  Romania)  provided  no  information  or 
incomplete information for Article 5;  

  On the energy audit  obligation (Article 8 EED), only Austria and Romania did not 
report information on the number of large companies for 2021. Much data for 2020 
were  missing,  with  only  Austria,  Belgium,  Croatia,  Cyprus,  Estonia,  France, 
Hungary, Ireland, Italy, Latvia, Luxembourg, Poland and Sweden reporting both the 
number  of  large  companies  and  the  energy  audits  carried  out  (for  the  latter 
category, Romania also reported data);  

  On  the  integrated  reporting  on  research,  innovation  and  competitiveness  (Article 
25), some Member States (Austria, Italy, Romania) did not report information on 
the financing of PaMs, while those that did often provided incomplete or inconsistent 
data. This lack of proper reporting on investment needs and funding sources fails to 
accurately  identify  funding  needs  and  gaps,  which  is  central  to  sound  strategic 
planning  and  implementation.  Nor  does  it  allow  for  the  effectiveness  of  public 
support and its impact on public finances to be assessed; 

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  On  the  annual  report  on  2020  energy  targets  (Article  27),  there  was  a  lack  of 
information in the 2020 target reports, with gaps in some cases corresponding to 
gaps in previous reports.  

Timeliness of information  

Timely submission of the draft NECPs was not always asusred. Nevertheless, it is unclear 
whether  this  problem  is  directly  linked  to  the  Governance  Regulation  or  results  from 
practices  and/or  procedural  bottlenecks  at  Member  State  level.  There  were  significant 
delays in the submission of LTSs, resulting in delays and inefficiencies in the Commission’s 
EU-wide assessment of the LTSs. There are indications that the lack of timeliness in the 
submission of LTSs derives from both insufficient national administrative capacity to fulfil 
the  reporting  obligations  under  the  Governance  Regulation  and  the  sequencing  of  the 
planning  and  reporting  obligations  (e.g.  NECPs  deadline  prior  to  the  LTSs  deadline). 
Nevertheless, there is no evidence that the Governance Regulation itself prevented timely 
LTSs submission. Rather, enforcement and administrative burdens seem to have delayed 
the submission of LTSs. The evaluation finds that the biennial progress reports and their 
follow up (NECPRs and reporting obligations stemming from Article 17 of the Governance 
Regulation)  were  submitted  either  on  time  or  with  a  small  delay,  not  impacting  the 
effectiveness  of  the  Governance  Regulation.  The  timeliness  of  information  on  PaMs 
remained  stable  between  2017  and  2019,  improved  in  2021,  then  decreased  in  2023. 
Information on projections of anthropogenic GHG emissions by sources and removals by 
sinks improved in 2019 compared to 2017, but deteriorated in 2021. However, evaluation 
finds no lack of effectiveness that can be attributed to the Governance Regulation.  

(Public) accessibility of information  

The  Governance  Regulation  has  increased  (public)  accessibility  of  information  to  some 
extent.  Stakeholders’  views  differ,  highlighting  areas  whree  the  public  accessibility  of 
information proved limited. However, it remains unclear whether these issues are linked 
to  the  Governance  Regulation  as  such  or,  more  likely,  to  implementation  issues  and/or 
national traditions across the EU.  

Planning processes and implementation of plans and reports 

The Governance Regulation has been effective in promoting better planning processes.  It 
helped to streamline the planning processes across the energy and climate domains, with 
increased cooperation among different ministries/authorities at national level. On NECPs, 
the evaluation finds that while the Governance Regulation enhanced planning to a sufficient 
extent,  some  issues  with  data  completeness  persist.  Nevertheless,  in  several  Member 
States, NECPs are not particularly relevant for national planning processes and are mainly 
developed to meet the EU obligation.  

The  evaluation  finds  that  varying  national  planning  traditions  negatively  impacted  the 
completeness of the LTSs, with Member States not reporting all mandatory content as per 
Article  15(4),  or  failing  to  do  so  coherently  with  their  NECPs.  Similarly,  LTSs  are  partly 
outdated and do not necessarily serve as the basis for NECP development. Stakeholders 
underlined the lack of attention paid to LTSs, including the absence of a close monitoring 
process for LTSs after their adoption (unlike NECPs).  

The  national  authorities  consulted  agreed  that  the  Governance  Regulation  influenced 
Member  States  to  adopt  or  implement  PaMs  to  meet  national  energy  and  climate 
contributions.  Several  factors  have  negatively  affected  both  the  planning  processes  and 
the effective implementation of plans and reports.  

Enforcement  

A  key  limitation  of  the  Governance  Regulation  is  that  the  enforcement  mechanism  is 
primarily based on recommendations, which are not legally binding.  

Stimulating spending and investment  

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The Commission’s assessments reveal that NECPs lacked detail on investment needs and 
funding  sources.  This  was  confirmed  by  industry  stakeholders  consulted.  They  provided 
only  limited  feedback  on  the  Governance  Regulation’s  impact  on  stimulating  targeted 
spending and investments and creating increased predictability for investors.  

Stakeholders were not very knowledgeable about the objectives, obligations and outputs 
stemming  from  the  Governance  Regulation,  with  many  only  providing  feedback  on  the 
NECPs and LTSs. Many stakeholders were unable to comment on the situation before the 
Governance Regulation and were unable to link or attribute specific trends in spending and 
investment to the Regulation.  

Ensuring regional cooperation  

Both the 2019 EU-wide assessment of the draft NECPs and the 2020 EU-wide assessment 
of the final NECPs indicated the need for enhanced regional cooperation efforts. The 2020 
EU-wide assessment found that while Member States properly understood and described 
the need for regional cooperation (with some making use of existing regional forums), the 
full  potential  of  regional  cooperation  has  yet  to  be  realised.  The  2023  Commission 
assessment  of  progress  towards  the  objectives  of  the  Energy  Union  and  Climate  Action 
revealed  that  most  Member  States  reported  progress  in  implementing  regional 
cooperation,  with  many  reporting  advances  in  at  least  one  of  their  regional  cooperation 
initiatives  or  projects.  The  2023  EU-wide  assessment  of  the  draft  NECPs  also  confirmed 
that regional cooperation was evident to only a limited extent across the Member States 
and limited to specific areas (e.g. bilateral agreements on the security of gas supply).  

Ensuring adequate multi-level and multi-stakeholder dialogue and consultation 

The evidence showed that while the introduction of Articles 10 and 11 is perceived as a 
significant step forward, the Governance Regulation has not been particularly successful in 
ensuring adequate multi-level and multi-stakeholder dialogue and consultation, as several 
Member  States  failed  to  establish  public  consultation  or  quality  multi-level  and  multi-
stakeholder dialogue.  

5.1.1.1  EQ1  -  To  what  extent  has  the  Governance  Regulation  led  to  increased 
quality,  increased timeliness,  and increased (public)  accessibility  of the 
reported  information  across  the  Energy  Union’s  five  dimensions  and 
regarding all aspects of relevance to the Regulation’s objectives, notably 
in terms of NECPs, LTSs and annual and biennial reports? 

The answer to this question is split into three sub-sections, presenting the findings on the 
extent to which the Governance Regulation led to (i) increased quality, (ii) timeliness, and 
(iii) (public) accessibility of the information across the Energy Union’s five dimensions, and 
regarding all aspects of relevance to the Regulation’s objectives, notably in terms of NECPs, 
LTSs and annual and biennial reports.  

One  of  the  general  objectives  of  the  Governance  Regulation  (General  Objective  3)  is  to 
ensure that reporting to the UNFCCC Secretariat is timely manner, transparent, and based 
on data that are accurate, consistent, and comparable. Accordingly, a specific objective of 
the Governance Regulation is to develop LTSs, NECPs, NECPRs, and additional annual and 
biennial  reports  (Specific  Objective  1).  To  do  so,  the  Governance  Regulation  focuses  on 
various activities:  

  Production of the NECPs and NECPRs  required  by the Governance Regulation and 
the running of national systems for GHG emissions inventories and PaMs (Member 
States);  

  Assessing  the  NECPRs  and  NECPs,  monitoring  responses  to  insufficient  progress, 
producing the State of the Energy Union report, reviewing data on national systems 
for GHG emissions, and maintaining Union systems (European Commission);  
  Running public consultations and multi-level energy dialogues at national level (with 
local  authorities,  civil  society  organisations,  business  community,  investors,  the 
public  and  other  relevant  stakeholders),  as  well  as  ensuring  ongoing  dialogue 

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between the Commission and Member States to ensure coherence between national 
and Union policies and objectives of the Energy Union.   

The Governance Regulation expects to improve: a) the quality of the quantitative data and 
statistics reported, as well as complementary qualitative information; b) the transparency 
of planned measures, investments, policies, and market trends; and  c) the  efficiency  of 
reporting processes, their easier reuse and integration; d) planning of climate and energy 
policies.  

Improved quality of information  

The evaluation finds that the Governance Regulation has led to improved quality 
of  information  across  the  Energy  Union’s  five  dimensions  and  on  all  aspects  of 
relevance  to  the  Regulation’s  objectives,  notably  NECPs  and  LTSs.  However, 
significant  variations  were  reported  across  Member  States,  depending  on  how 
the  Regulation  is  implemented  at  national  level.  Stakeholders'  differed  on 
whether the wording of the Governance Regulation is sufficiently prescriptive or 
whether it should retain flexibility to account for national variations.  

The 2016 IA preceding the introduction of the Governance Regulation stressed that one of 
the  general  objectives  (General  Objective  3)  should  be  ‘to  minimise  the  administrative 
burden and achieve a simplification and integration of planning, reporting and monitoring 
obligations  for  Member  States  and  the  Commission,  while  maintaining  benefits  of  such 
obligations  including  their  quality  of  information  and  transparency’.  To  achieve  this 
objective, the Governance Regulation requires EU Member States to:  

  Produce NECPs for 2021 to 2030 by 31 December 2019, update them by 30 June 
2023 and every 10 years thereafter, and prepare new NECPs by 1 January 2029 and 
every 10 years thereafter (Article 14);  

  Prepare  LTSs  with  a  30-year  perspective  and  report  them  to  the  European 
Commission, with a view to contributing to broader sustainable development goals 
and the long-term goals set by the Paris Agreement (Article 15);    

  Produce  biennial  progress  reports  on  the  implementation  of  the  plans,  from  15 
March  2023  onwards,  to  track  progress  across  the  five  dimensions  of  the  Energy 
Union (Article 17). 

  The  Governance  Regulation  established  a  consultation  process  involving  the 
Commission  and  Member  States  to  foster  regional  cooperation  between  Member 
States,  in  particular  before  NECPs  are  finalised.  The  Regulation  requires  the 
Commission to monitor and assess Member States’ progress towards  the targets, 
objectives and contributions set out in their NECPs. It also sets out the requirements 
for  (a)  national  and  EU  inventory  systems  for  GHG  emissions,  (b)  PaMs,  and  (c) 
projections. 

The  evaluation  finds  that  the  Governance  Regulation  has  contributed  to  an  overall 
improvement in the quality of the information reported. However, certain specificities are 
identified  in  relation  to  the  quality  of  information  on  each  reporting,  planning,  and 
monitoring obligation laid down by the Governance Regulation. 

The majority (55 %) of stakeholders surveyed indicated that the Governance Regulation 
has contributed to more complete, reliable, and accessible data ‘to some extent’. National 
authorities were the most positive, with almost half (14 of 30 respondents, 47 %) reporting 
that it has contributed ‘to a large extent’ or ‘to a very large extent’. Two of 30 respondents 
(14 %)  considered  the  effects  of  the  Governance  Regulation  to  have  improved  data 
completeness, reliability, and accessibility ‘only to a small extent’ (11 %), and one selected 
'not at all’ (3 %) (see Figure 4). 

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Figure 4.  Stakeholders’  views  on  information  contained  in  Member  States’  plans  and 

reports 

Source: ICF, based on targeted surveys. 

When asked whether the Governance Regulation has increased the quality or usefulness 
of information in their Member State, the national authorities that disagreed specified that 
mechanisms  for  the  EU  reporting  of  climate  policies  existed  prior  to  the  Governance 
Regulation42. This does not necessarily mean that the Regulation has not been effective, 
but, rather, recognises that the effects may have been less noticeable in Member States 
with (reportedly)  strong pre-existing frameworks. Two national authorities stressed that 
the indicators introduced by the Governance Regulation are of limited added value, as their 
Member States had already adopted national legislation monitoring those same aspects43. 
Similarly, a business association representing the transport sector pointed out that, data-
wise, certain Member States provide lesser-quality and poorly communicated data44.  

Compared  to  the  baseline,  however,  the  Governance  Regulation  improved  the 
transparency, quality and effectiveness of the reporting requirements, notably for aspects 
not previously effective or unnecessarily scattered across heterogeneous obligations (see 
section  4.1).  The  integrated  reporting  on  national  adaptation  actions,  financial  and 
technology support provided to developing countries and auctioning revenues (Article 19) 
constitutes an important and illustrative example of the role of the Governance Regulation 
in improving the availability of certain information (see Box 1).   

42 Open-text question responses from 2 national competent authorities (NCAs) (DK, FI).  
43 Open-text question responses from two NCAs (DK, FI).  
44 Interview with one industry transport association.  

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Box 1. 

Changes  to  national  adaptation  actions  –  adaptation  reporting  after  the 
Governance Regulation compared to the baseline 

Prior  to  the  Governance  Regulation,  reporting  on  national  adaptation  actions,  financial 
and  technological  support  to  developing  countries,  and  the  use  of  auctioning  revenues 
took place under different frameworks and obligations at EU and international level. The 
Governance  Regulation  streamlined  these  reporting  requirements  into  a  more  cohesive 
framework,  improving  transparency,  coordination,  and  the  effectiveness  of  EU  climate 
action efforts.  

On  national  adaptation  actions  –  adaptation  reporting,  for  example,  the  EU  Adaptation 
Strategy  encouraged  Member  States  to  adopt  national  adaptation  strategies  and  plans 
before the Governance Regulation, but there was no unified reporting requirement at EU 
level.  Reporting  on  adaptation  measures  was  more  fragmented  and  primarily  shared 
through various networks and platforms, such as the Climate-ADAPT platform, without a 
standardised reporting framework.  

While  the  fact  that  the  Governance  Regulation  streamlined  planning  and  reporting  and 
made  certain  information  more  readily  available  (to  all  stakeholders,  including  policy 
makers,  investors,  and  the  general  public),  this  does  not  necessarily  imply  that  it 
contributed  to  better  quality  or  more  relevant  information,  as  national  planning  and 
reporting approaches may continue to affect the quality of the information provided. This 
consideration  does  not  necessarily  imply  that  the  Governance  Regulation  lacks 
effectiveness  but  may  highlight  that  the  varied  style  across  the  EU  Member  States  can 
affect the quality of information reported.  

Integrated NECPs  

Chapter  2  (Articles  3-14)  of  the  Governance  Regulation  lays  down  the  rules  on  NECPs, 
including  their  procedural  aspects  (process)  involving  the  Member  States  and  the  EU 
Commission.  NECPs  should  address  the  five  dimensions  of  the  Energy  Union: 
decarbonisation;  energy  efficiency;  energy  security;  internal  market;  and  research, 
innovation, and competitiveness.  

The quality of the information on the five dimensions of the Energy Union reported through 
NECPs  constitutes  a  key  element  of  General  Objective  3  of  the  2016  IA  and  achieving 
General Objective 3 and Specific Objective 1 of the Governance Regulation. The Regulation 
therefore  represents  a  key  instrument  of  the  EU’s  energy  and  climate  legislative 
framework,  streamlining  the  different  climate  and  energy  planning  and  reporting 
requirements (NECPs and NECPRs). 

The Governance Regulation specifies the process to be followed by Member States and the 
Commission for the preparation, revision and finalisation of the NECPs (see Figure 5).  

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Figure 5.  Process for the preparation, revision and finalisation of NECPs (Chapter 2 of the 

Governance Regulation) 

Source: ICF, based on the Governance Regulation.  

Note: timeline until 2023, corresponding to the cut-off date for the evaluation. 

Annex I of the Governance Regulation details a ‘General Framework for Integrated National 
Energy and Climate Plans’ with which Member States must comply when preparing their 
NECPs.   

In 2019, the Commission analysed the draft NECPs and published an EU-wide assessment, 
as  well  as  CSRs.  The  assessment  found  that  the  draft  NECPs  did  not  provide  sufficient 
detail on some elements across the five dimensions of the Energy Union.45  

In September 2020, the Commission published an EU-wide assessment of the final NECPs. 
It  highlighted  that  all  EU  Member  States  had  submitted  good  quality  final  plans  that 
followed  a  comparable  structure  and  covered  integrated  national  objectives  and  policies 
for all dimensions of the Energy Union 46. However the final NECPs ‘did not always detail 
with sufficient precision actions and measures in important dimensions, such as identifying 
investment needs, sources of funding, research, innovation and competitiveness, regional 
cooperation, land use, land use change and forestry, just transition and energy poverty’ 47. 
In  some  dimensions  (e.g.  research  and  innovation  (R&I)),  definitions  and  approaches 

45 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions, United in delivering the Energy Union and Climate Action - 
Setting  the  foundations  for  a  successful  clean  energy  transition,  COM(2019)  285  final,  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52019DC0285  

46 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee  and  the Committee  of  the  Regions,  An  EU-wide  assessment  of  National  Energy  and Climate 
Plans:  Driving  forward  the  green  transition  and  promoting  economic  recovery  through  integrated  energy  and 
climate 
https://eur-lex.europa.eu/legal-
564 
content/EN/TXT/PDF/?uri=CELEX:52020DC0564  
47 Ibid., p. 26. 

COM(2020) 

planning, 

final, 

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varied between NECPs. While the quality of the final NECPs had improved compared to the 
draft NECPs, there was room for improvement in their completeness.  

More  recently,  the  Commission’s  2023  EU-wide  assessment  of  the  draft  updated  NECPs 
noted ‘several gaps, both in terms of maintaining the EU’s overall ambition and in terms 
of meeting the specific requirements set under EU legislation’, with this being ‘a matter of 
serious concern and of credibility for many Member States’48.  

Table 1 summarises the findings of the 2019 EU-wide assessment of the draft NECPs, the 
2020  EU-wide  assessment  of  the  final  NECPs,  and  the  2023  EU-wide  assessment  of  the 
draft updated NECPs. 

48 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions, 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,  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2023%3A796%3AFIN&pk_campaign=preparatory&pk_source=EURLEX&pk_medi
um=TW&pk_keyword=EUGreenDeal&pk_content=Communication&pk_cid=EURLEX_todaysOJ 

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Table 1.  Summary of 2019 EU-wide assessment of draft NECPs49, 2020 EU-wide assessment of final NECPs50, and 2023 EU-wide assessment of revised draft NECPs 51 

Dimension 

2019 EU-wide assessment of draft NECPs  

2020 EU-wide assessment of final NECPs  

2023 EU-wide assessment of revised draft NECPs  

Final Evaluation Report 

Decarbonisation 

  GHG emissions and removals: 

  GHG and removals: 

  Several draft NECPs would benefit from providing further details 
on the strategy for reaching the non-ETS targets over the entire 
period  2021-2030,  including  estimates  for  the  emission 
reduction trajectory based on latest data and the intended use 
of flexibilities. 

  Transport  is  responsible  for  around  one-quarter  of  GHG 
emissions in the Union and is the largest sector by emissions 
under  Member  States’  non-ETS  targets.  It  therefore  needs  to 
be  at  the  centre  of  the  NECPs.  Most  Member  States  set  out 
emission  reduction  measures  in  the  transport  sector.  Some 
already combine quantified emission reduction objectives with 
planned measures. In their final plans, Member States should 
be  more  concrete,  and  a  number  still  need  to  quantify  the 
expected impacts. Electromobility is often among the objectives 
pursued, but measures are often not described in detail52. 

 
  Enhancing the quality of MRV of emissions and removals, as per 
the  conclusions  of  the  2023  revision  of  the  LULUCF 
Regulation53. 

 

  Renewable energy: 

  Member States were required to list climate adaptation goals in 
their  NECPs,  where  available  and  as  applicable  to  achieve 
Energy  Union  objectives.  Although  national  adaptation 
strategies are available in all Member States and the changes 
in  climate  are  affecting  the  entire  EU,  around  one-quarter  of 
Member  States  have  not  listed  such  goals,  and  some  limit 
themselves to describing the framework for adaptation policy-
making, without quoting the goals themselves.  

 

  Renewable energy: 

  NECPs provide a clear signal from Member States that they back 
the  rapid  and  cost-effective  transition  to  a  resilient  carbon-
neutral economy, strongly based on renewables, which will help 
the private sector to invest confidently. For example, at least 10 
Member States have indicated their intention to phase out coal 
production  of  electricity  in  the  coming  years,  with  the 
decommissioned  capacity  replaced  mainly  by  renewable 
technologies.  However,  NECPs  fall  short  of  identifying  the 
potential  of  available  offshore  renewables  and  related 
challenges. 

 

  The final plans should provide robust information on PaMs that 
support  the  timely  achievement  of  Member  States’  proposed 
objectives and contributions for renewable energy. PaMs need 
to demonstrate that the proposed objectives and contributions 
can be achieved, notably in view of the first reference point set 
for 2022. 

 
  To  provide  guidance  to  market  players  and  attract  new 
investments  in  renewable  generation,  Member  States    main 
policies  and  measure  should  detail  elements  such  as  (i) 
expected  results,  (ii)  indicative  timeline,  (iii)  source  and 
amount of budget required. 

Energy efficiency 

  The  final  plans  need  to  be  more  robust  and  indicate  clearer 
energy consumption trajectories. Better definition of the overall 

  Final plans include more details on electrification in line with the 
EEF  principle55.  Co-benefits  and  possible  trade-offs  between 
energy  efficiency  measures  and  climate  adaptation  remain 

  GHG and removals: 
  Enabling  measures  from  Member  States  are  needed  to  put  in 
place sufficient PaMs in transport, buildings, agriculture waste, 
and to enhance carbon removal. This extra effort is needed to 
fill the gaps in reaching the targets under the ESR and LULUCF 
Regulation.  

 
  The land-use, forestry and agriculture sectors will play a crucial 
role  in  achieving  the  EU’s  climate  neutrality  and  adaptation 
objectives  through  reductions  of  GHG  emissions,  enhanced 
carbon removal, and ecosystem services to improve resilience. 
The Commission’s 2022 guidelines stipulated that NECPs should 
reflect the increased ambition proposed for the revision of the 
LULUCF Regulation by setting out the pathway towards national 
targets,  and  seek  synergies  between  the  CAP  strategic  plans 
(CSPs),  including  quantifying  their  expected  impact.  However, 
the majority of the draft updated NECPs do not show sufficient 
ambition  and  action on  land.  Very  few  Member  States  show  a 
concrete  pathway  to  reach  their  national  LULUCF  net  removal 
targets  for  2030,  or  sufficient  actions  to  assist  farmers, 
foresters,  and  other  stakeholders  in  building  sustainable 
business models in line with these targets54.  

 
  Renewable energy 
  The  share  of  renewable  energy  in  FEC  could  reach  between 
38.6 % and 39.3 % in 2030 at Union level. This is significantly 
higher than the 32 % set in RED II, yet lower than the binding 
target  of  42.5 %,  with  the  collective  endeavour  to  achieve  a 
target of 45 % set in the 2023 revised RED II. Very few Member 
States have submitted a contribution in line with their expected 
national contribution under the Governance Regulation and the 
revised RED II. 

 

 

In  energy  efficiency,  the  2030  FEC  at  Union  level  could  reach 
814.3 Mtoe, corresponding to a reduction of 5.8 % compared to 
2030 projections. This is lower than the 956 Mtoe FEC level set 

49 Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, United in delivering the Energy Union and Climate Action - Setting the foundations for a successful 
clean energy transition, COM(2019) 285 final, p. 8, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52019DC0285  
50 Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, An EU-wide assessment of National Energy and Climate Plans: Driving forward the green transition and 
promoting economic recovery through integrated energy and climate planning, COM(2020) 564 final, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020DC0564  

51 Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, EU-wide assessment of the draft updated National Energy and Climate Plans An important step towards 
the 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2023%3A796%3AFIN&pk_campaign=preparatory&pk_source=EURLEX&pk_medium=TW&pk_keyword=EUGreenDeal&pk_content=Communication&pk_cid=EURLEX_todaysOJ  

RePowerEU, 

COM(2023) 

objectives 

ambitious 

European 

climate 

energy 

Green 

under 

more 

2030 

final, 

Deal 

796 

and 

and 

the 

52 Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, United in delivering the Energy Union and Climate Action - Setting the foundations for a successful 
clean energy transition, COM(2019) 285 final, p. 8, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52019DC0285  
53 See: https://climate.ec.europa.eu/eu-action/land-use-sector_en#eu-rules-on-land-use-land-use-change-and-forestry-lulucf; Annex to the Communication to the Commission: Approval of the content of a draft Commission Notice on the Guidance to Member States 
for the update of the 2021-2030 national energy and climate plans, C(2022), 8263 final, https://energy.ec.europa.eu/system/files/2022-12/C_2022_8263_Guidance%20to%20MS%20NECP_2.pdf  
54 Commission Notice on the Guidance to Member States for the update of the 2021-2030 national energy and climate plans, C(2022) 495/02, Section 2.3.  
55 Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, An EU-wide assessment of National Energy and Climate Plans: Driving forward the green transition and 
promoting economic recovery through integrated energy and climate planning, COM(2020) 564 final, p. 6, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020DC0564  

June, 2024 

35 

 
 
 
 
 
 
 
 
 
  
 
 
 
Final Evaluation Report 

Dimension 

2019 EU-wide assessment of draft NECPs  

2020 EU-wide assessment of final NECPs  

2023 EU-wide assessment of revised draft NECPs  

framework  underpinning 

national  policy 
the  national 
contributions is key for ensuring credibility of the proposed level 
of  ambition,  identification  of  gaps  and  best  practice.  A  more 
detailed  explanation  of  the  scale,  timeframe  and  expected 
energy savings of the planned PaMs is needed. 

unrecognised and untapped. As additional action is necessary in 
the built environment, it is welcome that NECPs include various 
energy  efficiency  measures  in  the  building  sector.  In  general, 
there is broad coverage in all NECPs (and in the national LTRSs 
submitted  so 
far)  of  supportive  measures  to  building 
renovation. 

 

in the 2018 EED, yet higher than the 763 Mtoe, corresponding 
to a reduction of 11.7 % compared to 2030 projections in the 
EED  recast.  Only  a  handful  of  Member  States  propose  a 
sufficient  level  of  ambition  on  primary  energy  consumption 
(PEC), FEC or both.  

Energy security 

  More  concrete  objectives  and  targets  with  concrete  timelines 
would  better  inform  political  discussions  around  the  final 
NECPs. 

  Member States are encouraged to identify other types of risks, 
such as those associated with raw material supply, the impacts 
of climate change or accidental, man-made, natural, or terrorist 
threats to critical energy infrastructure in the final versions of 
their NECPs. 

  A number of NECPs acknowledge energy efficiency and domestic 
renewables as key factors contributing to their energy security 
(Malta,  Luxembourg,  France,  Lithuania,  Portugal).  Although 
most  Member  States  flag their  energy  sector  as  vulnerable  to 
climate change in their national adaptation strategy or even in 
the  decarbonisation  chapter,  only  five  Member  States  have 
proposed corresponding measures under the chapter on energy 
security. 

 
  Member  States  need  to  identify  PaMs  from  NECPs  to  improve 

preparedness and enhance resilience. 

  Energy  security  is  addressed  very  differently  across  the  draft 
plans.  EU  energy  imports  from  Russia  have  decreased 
significantly (e.g. Russian natural gas imports decreased from a 
share of around 45 % of EU imports in 2021 to 15 % during the 
first 10 months of 2023). However, only some Member States 
provide detailed plans for diversified access to gas or low carbon 
energy  sources.  The  demand  side  of  the  electricity  sector  and 
energy  storage  are  insufficiently  covered,  despite  the  growing 
importance of flexibility. Few Member States have set out how 
they plan for the gradual decline in oil use and its implications 
for energy security and oil infrastructure.  

Internal 
market  

energy 

  NECPs need to provide more detailed information on the current 
state  of  national  electricity  and  gas  markets  and  how  the 
challenges  will  be  tackled.  Concrete  and  measurable  national 
objectives for future market development should be included, 
supported by appropriate PaMs. 

  Although most Member States recognise the importance of the 
new  electricity  market  design,  only  some  take  a  holistic 
approach  to  necessary  changes  in  forward-looking  objectives. 
Many  plans  lack  key  information  on  competition  and  market 
liquidity. A considerable number of NECPs refer to smart-meter 
deployment with a specific and measurable target as enabling 
consumers to actively participate in the market. However, few 
set specific objectives and clear timelines, making it difficult to 
monitor progress towards targets. 

 
  The  final  plans  show  a  slight  improvement in  the  reporting  of 
energy and fossil fuel subsidy amounts and measures to phase 
them out.  Providing the  necessary  details  would  be important 
for any assessment of the extent to which fossil fuel subsidies 
in place are hampering climate objectives. 

  All  Member  States  have  started  to  phase  out  fossil  fuels  for 
energy generation, notably solid fossil fuels, but only a few are 
already coal-free, and not all plan to become coal-free by 2030. 
Some  Member  States  appear  to  be  backtracking  on  previous 
commitments  in  the  Territorial  Just  Transition  Plans  approved 
by the Commission in 2022. On fossil fuel subsidies, a collective 
effort by Member States is necessary to set a clear and credible 
timeline for their phase out. 

  Most  Member  States  identify  the  uptake  of  flexibility  and 
demand response as a key feature of the internal energy market 
to  ensure  rapid  penetration  of  renewable  energy,  and  some 
have put forward clear national objectives to support the uptake 
of  such  services.  Nevertheless,  clear  objectives  and  a 
comprehensive  regulatory  framework  to  reinforce  electricity 
grids to integrate renewables and technological innovations to 
encourage the uptake of flexibility assets are still missing in a 
number of plans.  

  To  address  energy  poverty,  a  vast  majority  of  Member  States 
still  need  to  set  out  clear  objectives  and  a  method  for  the 
definition and assessment of vulnerable households. Synergies 
with  structural  energy  policies,  particularly  energy  efficiency 
measures  and  a 
consumer 
empowerment  to  alleviate  energy  poverty,  are  not  sufficiently 
explored. 

framework 

stronger 

for 

Research, 
innovation 
competitiveness 

and 

  Member  States  need  to  make  additional  efforts  to  integrate 
research, innovation and competitiveness into their NECPs. 

 

  The final NECPs fail to pay sufficient attention to R&I needs for 
delivering  climate  and  energy  objectives.  There  is  an  overall 
decrease  in  national  budgets  devoted  to  R&I  in  clean  energy 
technologies  and  a  severe  lack  of  national  objectives  and 
funding  targets  that  show  concrete  and  relevant  pathways  to 
2030  and  2050.  Most  of  the  plans  only  outline  funding  of 
existing non-energy specific programmes that run for less than 
five years. 

  Given these challenges, the Commission will put a renewed and 
stronger  focus  on  research,  innovation  and  competitiveness, 
including on preparing a skilled workforce. The Commission will 
work with Member States to prepare their NECPs with reforms 
that aim to keep clean energy prices affordable for citizens and 
households. Extra focus on competitiveness and innovation in a 
simplified regulatory environment is needed if EU business is to 
conceive,  develop,  and  expand  production  capacities  for clean 
technologies  and  secure  the  supply  of  components  and 

June, 2024 

36 

 
 
 
 
 
 
 
 
 
 
 
Dimension 

2019 EU-wide assessment of draft NECPs  

2020 EU-wide assessment of final NECPs  

2023 EU-wide assessment of revised draft NECPs  

Final Evaluation Report 

  The approach to competitiveness varies between NECPs. Some 
followed a narrow definition looking at patents and researchers, 
or  power  prices.  Other  plans  cover  technology  deployment 
aspects  and thus  take  a  broader  competitiveness  approach to 
national  suppliers  of  clean  technologies,  including  the  value 
chains  to  develop  such  solutions.  However,  most  plans  lack 
quantitative indicators and are not measurable. 

materials  across  the  entire  value  chain,  in  line  with  the  NZIA 
and the Critical Raw Materials Act. 

Sources: Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, United in delivering the Energy Union and Climate Action - Setting the foundations for a successful 
clean energy transition, COM(2019) 285 final; Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, An EU-wide assessment of National Energy and Climate 
Plans: Driving forward the green transition and promoting economic recovery through integrated energy and climate planning, COM(2020) 564 finalhttps://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020DC0564; Communication from 
the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, 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. 

June, 2024 

37 

 
 
 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the 
Energy Union and Climate Action 

To ensure comparability, the Governance Regulation provides templates for Member States 
to  draft  their  NECPs  (Annex  I)  and  LTSs  (Annex  IV).  It  also  mandates  the  European 
Commission  to  adopt  implementing  acts  setting  out  templates  for  other  reporting 
obligations56,57.  

Implementing  Regulation  (EU)  2020/1208  establishes  rules  on:  (a)  Member  States’ 
reporting on national adaptation actions, the use of auctioning revenues, and financial and 
technology  support  provided  to  developing  countries  pursuant  to  Article  19  of  the 
Governance Regulation; (b) Member States’ reporting on approximated GHG inventories, 
GHG inventories and accounted GHG emissions and removals pursuant to Article 26 of the 
Governance Regulation; (c) requirements on the establishment, operation and functioning 
of national inventory systems pursuant to Article 37; (d) the timing and the procedure for 
carrying  out  the  comprehensive  review  pursuant  to  Article  38  of  the  Governance 
Regulation;  (e)  Member  States’  reporting  on  national  system  for  PaMs  and  projections 
pursuant to Article 39 of the Governance Regulation.  

Implementing  Regulation  (EU)  2022/2299  establishes  rules  on  the  structure,  format, 
technical  details,  and  process  for  the  integrated  NECPRs  pursuant  to  Article  17  of  the 
Governance Regulation, and provides (in its annexes) templates for reporting obligations 
(e.g. national objectives, targets and contributions; PaMs), some of which are voluntary.  

In 2022, the Commission published its Guidance to Member States for the update of the 
2021-2030 NECPs58. While preparing the guidance, the Commission engaged with Member 
States  at  technical  level  and  consulted  with  stakeholders.  A  technical  working  group  on 
NECPs  was  also  set  up.  Although  the  Governance  Regulation  provides  a  legally  binding 
template for the NECPs, there was still considerable diversity in Member States’ approaches 
to reporting information and detailing measures to achieve objectives and targets59. Two 
NCAs  consulted  mentioned  that  the  rigid  structure  for  the  NECPs  was  an  obstacle  to 
providing  information  in  a  meaningful  way,  or  did  not  suitably  reflect  the  country’s 
framework or context.  

According  to  one  third  sector  organisation  interviewed,  NECPs  were  generally  of  good 
quality  and  their  comparability  was  much  enhanced  by  the  template.  However,  eight 
respondents to the CfE mentioned that the template was not fit for purpose and should be 
revised to ensure that Member States can include an adequate level of information 60.  

The evaluation finds that while the Governance Regulation improved the accuracy of the 
reported information to a sufficient extent, there are some persistent gaps and issues with 
the completeness of data. There are indications that individual Member States have taken 
divergent approaches, potentially influencing the nature of the information collected. The 
evaluation  finds  that  the  inaccuracies  of  the  available  data  included  in  the  NECPs  (e.g. 

56  Commission  Implementing  Regulation  (EU)  2020/1208  of  7  August  2020  on  structure,  format,  submission 
processes and review of information reported by Member States pursuant to Regulation (EU) 2018/1999 of the 
European Parliament and of the Council and repealing Commission Implementing Regulation (EU) No 749/2014, 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32020R1208&qid=1707831881860 
57  Commission  Implementing  Regulation  (EU)  2022/2299  of  15  November  2022  laying  down  rules  for  the 
application of Regulation (EU) 2018/1999 of the European Parliament and of the Council as regards the structure, 
format, technical details and process for the integrated national energy and climate progress reports, https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R2299&qid=1707831881860 
58  Commission  notice  on  the  Guidance  to  Member  States  for  the  update  of  the  2021-2030  NECPs,  C(2022), 
495/02. 
59  FIT  for  future  platform,  Opinion  on  the  Regulation  on  the  Governance  of  Energy  Union  and  Climate  Action, 
2022, Final opinion 2022_SBGR1_03 Governance of Energy and Climate_fup.pdf (europa.eu) 
60 Replies to CfE: NGOs (3): CAN Europe; Transport and Environment, Youth and Environment Europe; Business 
associations (4); European Association for External Thermal Insulation Composite Systems (ETICS); Renewable 
Energy Federation; EGEC Geothermal, Solar Power Europe; Environmental organisation: WWF European Policy 
Office.  

September, 2024 

38 

 
 
 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the 
Energy Union and Climate Action 

investments  in  specific  sectors,  such  as  wind  energy61)  reflect  national  approaches  and 
Member  States’  planning  policies,  rather  than  being  directly  attributable  to  insufficient 
effectiveness of the Governance Regulation. Nevertheless, the practical effect of this lack 
of  harmonisation  may  impact  the  effectiveness  of  the  Governance  Regulation  as  an 
exogenous  factor  linked  to  the  implementation  and  enforcement  of  the  Regulation  in 
practice.   

Four stakeholders consulted mentioned that while the Governance Regulation contributed 
to  increased  accuracy  of  NECPs’  reported  data,  quality  issues  included  varying 
completeness and level of detail62. In addition, when referring to NECP data quality, one 
third sector organisation interviewed indicated some divergence in the quality and clarity 
of the information provided, consistency between measures (including their explanation), 
and  quantification  of  the  objectives  set.  They  also  indicated  that  the  quality  of  the 
information depends on the Member State, with a sense that quality is insufficient and data 
lack  detail  and  clarity  (e.g.  expected  impact  of  the  policy  measure,  calculation  of  that 
impact, evidence used by Member State)63.  

One  climate  civil  society  organisation 64,  while  acknowledging  some  improvements  in 
comparability  and  standardisation  of  planning  and  reporting  procedures  and  therefore 
more  coherence  in  the  available  data,  pointed  to  several  quality  problems  that  have 
become apparent. For instance, the first set of NECPs that Member States provided lacked 
detail, quality and depth and were less comparable, thus stakeholders (including investors 
and policymakers) had different levels of information on which to base their decisions. Four 
stakeholders underlined that the NECPs are often a mere compilation of existing plans and 
policies65. According to one expert from a European institution, the NECPs are developed 
only  when  needed,  instead  of  being  used  as  ‘living  documents’  that  are  continuously 
updated66.  One  national  authority  explained  that  the  biennial  progress  report  was  more 
comprehensive and better quality67.   

The evaluation finds persistent gaps in the information reported in the NECPs, potentially 
impacting  the  accuracy  of  the  data.  Four  stakeholders  mentioned  information  gaps  in 
relation to investment needs, particularly sources of investment (existing or new measures, 
public budget or private funding sources)68. Other areas where a lack of information was 
highlighted  were:  a)  sourcing  of  forest  biomass  and  LULUCF  impact69;  b)  implication  of 
energy and climate policies for industry70; c) data on geothermal heat pumps, geothermal 
district heating and cooling systems71; and GHG projections 72. One stakeholder added that 
although the data on GHG projections has improved, this trend might not necessarily be 
related to the Governance Regulation73. Another underlined that reporting on adaptation 
measures has been scarce74.  

61 Stakeholder workshop: business association (1).  
62 Scoping interviews with EU institutions (3) and NCA (1). 
63 Interview with a third sector association (1).  
64 Interview with a third sector association (1) 
65  Replies  to  CfE:  Public  authority:  DK  Ministry  of  Climate,  Energy  and  Utilities.  Business  association:  EGEC 
Geothermal. Academic/Research institute: Wuppertal Institut für Klima, Umwelt, Energie. Scoping interview with 
NCA (1).  
66 Scoping interview with EU institution (1).  
67 Scoping interview with NCA (1). 
68 Replies to CfE: NGOs (2): Transport and environment; Renewable Grid Initiative; Environmental Organisation: 
WWF European Policy Office; Academic/Research Institute: Ecologic Institute.  
69 Replies to CfE: NGOs (2): FERN; Natural Resources Defence Council. 
70 Reply to CfE: NGO: Transport and Environment. 
71 Replies to CfE: Business association: EGEC Geothermal. 
72 Scoping interview with EU institution (1).  
73 Scoping interview with EU institution (1).  
74 Scoping interview with EU institution (1).  

September, 2024 

39 

 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the 
Energy Union and Climate Action 

At the stakeholder event organised by the Commission, participants were asked whether 
the  information  included  in  NECPs  on  planned  and  required  investment  is  relevant  to 
investors and civil society and used to inform investment decisions. Overall, participants 
expressed  a  positive  view  of  the  quality  of  information  on  investments  included  in  the 
NECPs (see Figure 6).  

Figure 6.  Participants’ poll at stakeholder event 

Source:  SLIDO  responses  (N=60;  average  responses  =  3.  Range  between  1=Low  and 
5=High. For instance, 1 indicating that the NECPs contain information relevant to investors 
and civil society only to a very small extent). 

A variety of sectoral views emerged, with stakeholders pointing out that certain information 
on  investments  is  still  inaccurate  or  generally  unclear.  For  instance,  one  business 
association stressed that when it comes to planning future solar panel capacities, the sector 
needs to understand and have clear information on when and where projects will happen 
– while the provisions of the Governance Regulation are quite satisfactory, there can be a 
gap between these provisions and long-term investment strategies75. A global network of 
local and regional governments committed to sustainable urban development specified that 
NECPs are still unclear on how the various initiatives will be funded (e.g. EU budget, local 
budget).  It  called  for  more  granular  data,  including  information  from  regional  and  local 
level 76.   

The Governance Regulation introduced and defined the EEF principle, which is intended to 
contribute to ‘the interlinkages between the five dimensions of the Energy Union’ (Article 
3(3)(a)).  References  to  the  EEF  principle  are  now  included  in  most  pieces  of  relevant 
legislation. One respondent to the CfE noted that the introduction of a legal definition of 
the  EEF  principle  proved  useful  in  raising  awareness  of  the  importance  of  prioritising 
demand-side resources. However, its inclusion did not lead to a systematic application of 
the  principle  in  national  policies  and  the  consideration  of  energy  demand  reduction 
measures on an equal footing with supply-side resources. One NCA reported that the EEF 

75 Stakeholder workshop: business association (1).  
76 Stakeholder workshop: third sector association (1). Another business association (1) expressed a similar view 
on the need for more granular information on investment needs.  

September, 2024 

40 

 
 
 
 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the 
Energy Union and Climate Action 

principle is not sufficiently covered in the Governance Regulation77. Echoing this point, a 
business association at the stakeholder event noted that the Governance Regulation does 
not give sufficient priority to energy efficiency.  

Finally,  several  stakeholders  highlighted  that  the  social  dimension  of  the  Governance 
Regulation  has  not  been  given  enough  attention  in  the  NECPs,  even  though  the  energy 
transition will impact workers and households78. Although many NECPs reported measures 
to address energy poverty79, these considerations should be given increased attention80.  

LTSs  

The entry into force of the Governance Regulation marked a significant evolution from the 
framework established by the MMR. Previously, strategies for energy, climate mitigation 
and  climate  adaptation  were  fragmented;  the  Governance  Regulation  enhanced  the 
requirements for integrated national planning and reporting, explicitly incorporating long-
term strategies for GHG emissions reduction and adaptation to climate change with those 
for energy. It sought to provide a more cohesive and comprehensive approach to meeting 
EU  energy  and  climate  goals,  aligning  with  international  commitments  under  the  Paris 
Agreement and facilitating the transition to a sustainable, low-carbon economy across the 
EU. 

Article 15 of the Governance Regulation sets out the obligations and processes for Member 
States  and  the  European  Commission  to  prepare  and  submit  the  long-term  low  GHG 
emission development strategies. It states that by 1 January 2020, and subsequently by 1 
January 2029 and every 10 years thereafter, each Member State shall prepare and submit 
to  the  Commission  its  LTS  with  a  perspective  of  at  least  30  years.  Where  necessary, 
Member States should update those strategies every five years (Article 15(1)). Figure 7 
presents a summary of the process for LTSs set out by the Governance Regulation.  

77 Interview with NCA (1).  
78 Replies to CfE: Environmental organisations (3): WWF European Policy Office; Estonian Fund For Nature, Baltic 
environmental organisations. NGOs (3): Transport and Environment, CAN Europe, EEB. Scoping interview with 
EU institution (1). 
79 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee  and  the Committee  of  the  Regions,  An  EU-wide  assessment  of  National  Energy  and Climate 
Plans:  Driving  forward  the  green  transition  and  promoting  economic  recovery  through  integrated  energy  and 
climate 
https://eur-lex.europa.eu/legal-
564 
content/EN/TXT/PDF/?uri=CELEX:52020DC0564; European Commission, ‘National Energy and Climate Plans for 
2021-2030  under  the  EU  Energy  Union’,  JRC  Science  for  Policy  Report:  Assessment  of  the  Energy  Efficiency 
Dimension, 
https://op.europa.eu/en/publication-detail/-/publication/2c751d22-4f07-11eb-b59f-
01aa75ed71a1/language-en   
80  Replies  to  CfE:  NGOs  (3)  Transport  and  Environment,  German  watch  e  V,  ZERO.  –  Association  for  the 
Sustainability of the Earth System. Environmental organisation: WWF European Policy Office. Scoping interview 
with EU institution (1). 

COM(2020) 

planning, 

final, 

September, 2024 

41 

 
 
 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the 
Energy Union and Climate Action 

Figure 7.  Summary  of  the  process  for  LTSs  laid  down  in  Article  15  of  the  Governance 

Regulation  

Source: ICF, based on Article 15 of the Governance Regulation. 

According to Article 15(4) of the Governance Regulation, Member States and the Union’s 
LTSs shall cover at least five topics: a) total GHG emission reductions and enhancements 
of removals by sinks; b) emission reductions and enhancements of removals in individual 
sectors,  including  electricity,  industry,  transport,  the  heating  and  cooling  and  buildings 
sector  (residential  and  tertiary),  agriculture,  waste  and  land  use,  LULUCF;  c)  expected 
progress  on  transition  to  a  low  GHG  emission  economy,  including  GHG  intensity,  CO2 
intensity of gross domestic product (GDP), related estimates of long-term investment, and 
strategies  for  related  research,  development  and  innovation  (RDI);  d)  to  the  extent 
feasible,  expected  socioeconomic  effects  of  decarbonisation  measures,  including  aspects 
related  to  macro-economic  and  social  development,  health  risks  and  benefits  and 
environmental  protection;  and  e)  links  to  other  national  long-term  objectives,  planning, 
other PaMs, and investment.  

Annex IV to the Governance Regulation sets out a General Framework for the LTSs and a 
non-mandatory template for their  compilation  by Member States. Unlike the  NECPs, the 
template for LTSs is not binding, nor is the update of the strategies every five years (Article 
15). Four respondents to the CfE mentioned that, compared to the NECPs, LTSs have not 
been  given  sufficient  attention81,  while  three  indicated  that  the  LTSs  template  lacks 
detail82.  According to a technical report commissioned by the European Climate Foundation 
in 202283 and assessing all the EU Member States’ LTSs, Annex IV was fully followed by 
five Member States84, partly followed by 12 Member States85, and not followed at all by 
five Member States86.   

On the completeness of the LTSs against the mandatory content set out in Article 15(4), 
the  technical  report  highlighted  that  13  EU  Member  States  were  compliant,  six  mostly 

81  Replies  to  CfE:  NGOs  (2)  CAN  Europe,  Transport  and  Environment.  Academic/Research  institute:  Ecologic 
Institute. Environmental organisation: WWF European Policy Office.  
82 Replies to CfE: NGO: Transport and Environment; Environmental organisation: WWF European Policy Office. 
Academic/Research institute: Ecologic Institute. 
83 Velten, E.K., Evans, N., Spasova, D., Duwe, M., de la Vega, R., Duin, L. and Branner, H., Charting a path to 
net  zero:  An  assessment  of  national  long-term  strategies  in  the  EU,  Ecologic  Institute,  Berlin,  2022, 
https://www.ecologic.eu/18646   
84 FI, HR, IT, MT, SK. 
85 AT, BE, DK, EE, EL, ES, HU, LT, LV, NL, SE, SI.  
86 CZ, DE, FR, LU, PT. 

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compliant, while three were mostly non-compliant. No country was found to be completely 
non-compliant. 

Table 2.  LTS compliant with mandatory content and timeframe  

Compliant 

Mostly compliant  Mostly 

non-

Non-compliant 

Austria  

Croatia 

Czechia 

Estonia 

compliant 

Belgium  

Denmark  

Finlandia 

Germany 

the Netherlands  

Francia 

Greece 

Hungary 

Slovenia  

Sweden  

Italy 

Latvia  

Lithuania 

Luxembourg  

Malta  

Portugal 

Slovenia 

Spain  

Total: 13 

Total: 6 

Total: 3 

Total: 0 

Source:  Ecologic,  Charting  a  Path  to  Net  Zero:  An  Assessment  of  National  Long-Term 
Strategies in the EU, Technical report, 2022, p. 60.  

The LTSs of Belgium, Denmark and the Netherlands were mostly non-compliant because 
they  omitted  crucial  sectoral  GHG  data  and  provided  little  or  no  information  on  the 
socioeconomic  dynamics  of  the  transition.  The  report  reflects  on  the  nature  of  the 
information in the LTSs insofar as it affects the quality of the available data, identifying 
two main shortcomings: an overall lack of quantitative data, especially in the long-term; 
and  a  general  lack  of  sector-specific  detail87.  This  is  related  to  the  fact  the  Governance 
Regulation  ‘does  not  specify  the  depth  or  type  of  information  (e.g.  quantitative  or 
qualitative) or the format of presentation nor does it spell out in concrete terms how the 
30-year time horizon should be addressed concretely’88. 

On the quality of the information in the LTSs, the study commissioned by the European 
Climate  Foundation  in  2022  suggests  that  the  Governance  Regulation  effectively 
contributed to improved accuracy of the available data around the five dimensions to be 
covered (Article 15(4) of the Governance Regulation). Nevertheless, the Ecologic study in 
2022 found that: (a) Member States’ national planning traditions influence the degree of 
completeness of their LTSs; (b) some Member States did not include all mandatory content 

87 Ibid., p. 61.  
88 Ibid.  

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as  per  Article  15(4)  of  the  Governance  Regulation;  (c)  there  are  indications  that  the 
information  in  the  LTSs  is  not  fully  coherent  with  the  information  in  the  NECPs,  despite 
Article  15(6)  requiring  Member  States  to  ensure  coherence89.  While  these  constitute 
important aspects of the LTSs within the Governance Regulation, they do not impact the 
quality  of  the  information  provided  in  the  LTSs.  Rather,  the  quality,  depth  and 
completeness of the available data seems to be primarily linked to the national planning 
traditions of the Member States.  

Biennial progress reports and their follow up  
Chapter  4,  Section  1  (Articles  17-25),  of  the  Governance  Regulation  requires  Member 
States to produce biennial progress reports on the implementation of their NECPs, from 15 
March 2023 onwards, to track progress across the five dimensions of the Energy Union.  

NECPRs 

According to Article 17 of the Governance Regulation, each Member State shall report to 
the Commission on the status of the implementation of its integrated NECP by means of 
an integrated NECPR covering all five dimensions of the Energy Union. Table 3 summarises 
the reporting obligation.  

Table 3.  Reporting obligation under Article 17 of the Governance Regulation  

Article 

Requirements 

Article 
17(2)(a) 

Information  on  progress  towards  reaching  the  objectives,  targets  and 
contributions set out in the integrated NECP, and towards financing and 
implementing  the  PaMs  necessary  to  meet  them,  including  a  review  of 
actual investment against initial investment assumptions 

Article 
17(2)(b) 

Where applicable, information on progress in establishing the dialogue 
referenced in Article 11 

Article 
17(2)(c) 

Information  referenced  in  Articles  20-25  and,  where  appropriate, 
updates on PaMs, in accordance with those articles 

Article 
17(2)(d) 

Information on adaptation in accordance with Article 4(a)(1) 

Article 
17(2)(e) 

As  far  as  possible,  quantification  of  the  impact  of  the  PaMs  in  the 
integrated NECP on air quality and on emissions of air pollutants 

Article 
17(3) 

The integrated NECPR shall cover the information contained in the annual 
reports  referenced  in  Article  26(3)  and  the  information  on  PaMs  and 
projections  of  anthropogenic  GHG  emissions  by  sources  and 
removals by sinks contained in the reports referenced in Article 18 

Source: Governance Regulation, Article 17. 

Article 17(2)(a) requires Member States to report on the information enabling the review 
of the actual investment against initial investment assumptions (see Table 4 for additional 
information  on  the  quality  of  data  on  investment  needs,  and  reporting  on  research, 
innovation,  and  competitiveness  (Article  25)).  However,  as  indicated  in  the  European 
Commission’s  assessment  of  progress  towards  the  objectives  of  the  Energy  Union  and 

89 8 ‘Somewhat coherent’, 5 ‘not coherent’, 3 ‘coherent’, 6 ‘mostly coherent’ (Velten, E.K., Evans, N., Spasova, 
D., Duwe, M., de la Vega, R., Duin, L. and Branner, H., Charting a path to net zero: An assessment of national 
long-term strategies in the EU, Ecologic Institute, Berlin, 2022, p. 60), https://www.ecologic.eu/18646).  

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Climate Action 90, the information provided by Member States is often missing, incomplete 
or  inconsistent.  For  example,  the  European  Commission  reported  that  several  Member 
States ‘did not sufficiently describe their multilevel climate and energy dialogues: some do 
not  refer,  for  instance,  to  the  periodicity  of  the  activities  reported,  the  long-term 
perspective,  the  active  engagement  process  with  the  local  authorities  or  with  key 
stakeholders, etc. Some only list punctual consultations or events without explaining the 
overall approach or how the initiatives listed are interlinked. Other Member States stated 
that they set-up multilevel climate and energy dialogues without describing sufficiently the 
parties involved nor the processes put in place (Czech Republic, Slovakia)’91. 

The reporting obligations of Article 17(2)(c) to (e) and 17(3) refer to Articles 18, 20, 21, 
22, 23, 24, 25 of the Governance Regulation, which specify the information that Member 
States  shall  report  in  their  NECPRs,  as  well  as  the  processes  between  the  European 
Commission and Member States. Table 4 summarises the main reporting obligations linked 
to Article 17 of the Governance Regulation.  

Table 4.  Reporting obligations stemming from Chapter 4 of the Governance Regulation 

Articles  Reporting obligation 

Article 
17 

Article 
18 

Integrated NECPRs 

Integrated reporting on GHG PaMs and projections 

Article 
19 

Integrated reporting on national adaptation actions, financial and technology 
support provided to developing countries and auctioning revenues 

Article 
20 

Article 
21 

Article 
22 

Article 
23 

Article 
24 

Article 
25 

Integrated reporting on renewable energy 

Integrated reporting on energy efficiency 

Integrated reporting on energy security 

Integrated reporting on the internal energy market 

Integrated reporting on energy poverty 

Integrated reporting on research, innovation and competitiveness 

Source: ICF, based on Article 17 of the Governance Regulation. 

The Commission’s technical assessment report concluded that data quality and availability 
vary between topics92. Table 5 summarises that report’s main findings on the provision of 
information.  

90 European Commission, Assessment of progress towards the objectives of the Energy Union and Climate Action, 
SWD(2023, 646 final. 
91 Ibid., p. 68.  
92 Ibid., p. 3.  

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Table 5.  Quality of reported information in the NECPRs  

Articles  Reporting obligation 

Assessment  

Article 
18 

Integrated  reporting  on  GHG  PaMs  and 
projections 

Progress  towards  national  objectives,  targets,  and  contributions  for  GHG  emissions 
reduction  

Article 
19 

Integrated  reporting  on  national  adaptation 
actions,  financial  and  technology  support 
provided 
to  developing  countries  and 
auctioning revenues 

All  Member  States  reported  their  progress  towards  national  objectives,  targets,  and 
contributions  (Annex  I).  However,  reports  varied  and  information  was  largely 
insufficient to provide a collective EU assessment (p. 6).  

Progress on climate adaptation action supporting the objectives of the Energy Union 

Monitoring and evaluation frameworks for adaptation goals are either recent or under 
development in the Member States, and operate under national adaptation strategies 
or  plans,  rarely  considering  synergies  with  the  Energy  Union  dimensions.  Thirteen 
Member States reported clear progress with the implementation of adaptation actions 
for each adaptation goal.  

Article 
20 

Article 
21 

Integrated reporting on renewable energy 

Renewable energy in buildings 

Integrated reporting on energy efficiency 

Exemplary role of public bodies’ buildings – Article 5 of the EED 

On  the  newly  introduced  reporting  categories  of  renewable  energy  consumed  and 
produced by buildings, only limited information was received from Member States and 
it was not easily comparable. 

The  public  sector  plays  an  important  exemplary  role  in  enhancing  energy  efficiency 
practices, with Article 5 of the EED setting out important requirements. Compared to 
the annual reports submitted in 2022, there was a lack of information on these issues 
in  the  reports  submitted  in  2023.  Four  Member  States  (Hungary,  Latvia,  Portugal, 
Romania) provided either no information or incomplete information for Article 5. 

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Articles  Reporting obligation 

Assessment  

Energy audit obligation – Article 8 of the EED 

To  optimise  energy  savings  in  the  industrial  sector,  Article  8  of  the  EED  requires 
companies  that  are  not  small  or  medium-sized  enterprises  (SMEs)  to  carry  out  an 
energy  audit  or  implement  an  energy  management  system  at  least  once  every  four 
years.  In  their  NECPRs,  Member  States  were  required  to  state  the  total  estimated 
number  of  large  companies  in  their  territory  to  which  Article  8(4)  of  the  EED  is 
applicable and the number of energy audits carried out in those enterprises. For 2021, 
only Austria and Romania did not report information on the number of large companies 
and Austria did not report the energy audits carried out in those companies. In 2020, 
much information on energy audits was missing, with only Austria, Belgium, Croatia, 
Cyprus,  Estonia,  France,  Hungary,  Ireland,  Italy,  Latvia,  Luxembourg,  Poland  and 
Sweden reporting both the number of large companies and the energy audits carried 
out (for the latter category, Romania also reported its numbers).  

Article 
25 

Integrated reporting on research, innovation 
and competitiveness 

Translating the Strategic Energy Technology (SET) Plan objectives and policies  

Currently, the SET Plan activities are clustered into 10 R&I actions, implemented by 14 
Implementation Working Groups (IWGs).  

The  information  in  the  reports  refers  to  ‘new  measures’  with  a  timeline  to  2030, 
preventing  assessment  against  pre-existing  targets.  Some  Member  States  (Austria, 
Italy,  Romania)  did  not  report  information  on  the  financing  of  PaMs,  while  those 
Member States that reported often submitted incomplete or inconsistent data. This lack 
of proper reporting on investment needs and funding sources fails to accurately identify 
funding  needs  and  gaps,  which  is  central  to  sound  strategic  planning  and 
implementation.  Nor  does  it  allow  assessment  of  the  effectiveness  of  public  support 
and its impact on public finances. 

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Articles  Reporting obligation 

Assessment  

Overall, the most important data gaps were actual investments made and appropriate 
accounting  of  the  source  of  the  funds  employed  (national  public,  European,  private 
funds). Several Member States failed to report any support from the EU budget, which 
appears  inconsistent  with  other  information  available  at  EU  central  level  (e.g. 
allocations from Cohesion Policy funds). 

Overall,  the  high  level  of  incomplete  data  on  support  does  not  allow  for  a  division 
between national, European and private funds allocated by the Member States. Nor is 
it  possible  to  compare  Member  States’  submissions,  as  timelines  for  investment 
assumptions  might  differ.  Implementation  periods  of  single  PaMs  reasonably  differ 
because  investment  assumptions,  especially  financial  allocations  to  specific  national 
financing  schemes/programmes  or  specific  investments,  are  determined  by  national 
procedures determining budgetary allocation for the specific measure. 

Source: European Commission, Assessment of progress towards the objectives of the Energy Union and Climate Action, SWD(2023, 646 final.

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Energy Union and Climate Action 

Integrated  reporting  on  GHG  PaMs  and  projections  (Article  18  of  the  Governance 
Regulation) 

Article  18(1)  of  the  Governance  Regulation  requires  Member  States  to  report  to  the 
Commission, by 15 March 2021, and every two years thereafter, on:  

  National PaMs or group of measures, as set out in Annex VI and (Article 18(1) point 

(a)); 

  National projections of anthropogenic GHG emissions by sources and removals by 
sinks,  organised  by  gas  or  group  of  gases  (Hydrofluorocarbons  (HFCs)  and 
Perfluorocarbons (PFCs)) listed in Part 2 of Annex V. National projections shall take 
into consideration any PaMs adopted at Union level and shall include the information 
set out in Annex VII (Article 18(1)(b)).   

A. PaMs 

In  2023,  EU  Member  States  reported  on  3 039  single  PaMs,  a  substantial  increase  on 
previous reporting years (see Figure 8). The increase in the number of single PaMs reflects 
Member States’ implementation of the NECPs and represents the extension of the reporting 
to dimensions of the Energy Union other than GHG emissions and removals. The increase 
in the number of reported PaMs in 2023 reflects the increase in scope of reporting.  

Figure 8.  Number of single PaMs reported per year 

Source: ICF, based on EEA reports.  

A review of the EEA reports shows that while the number of PaMs has increased over time, 
the  completeness  of  reported  information  (particularly  quantitative  information)  has  not 
improved.  

  In  2019,  completeness  of  both  qualitative  and  quantitative  information  improved 
compared  to  2017.  The  continued  use  of  a  single  online  questionnaire  and 
improvements  in  reporting  by  the  Member  States,  together  with  automatic  and 
manual checks to point out missing information, clearly contributed. However, while 
qualitative information was generally complete for all Member States, information 
on indicators, costs and benefits, and emission savings could have been expanded, 

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Energy Union and Climate Action 

particularly for ex-post emission savings and costs93. The quality of the information 
reported  in  2021  did  not  improve  substantially  in  terms  of  its  completeness, 
consistency,  accuracy,  and  transparency,  compared  to  2019.  Quantitative 
information  on  achieved  (ex-post)  policy  evaluations,  costs  and  benefits,  and 
indicators remained underreported94.  

  In 2023, the number of reported single national PaMs to reduce GHG emissions had 
increased since the last reporting cycle. Member States reported for the first time 
on national PaMs for all five dimensions of the Energy Union. The completeness of 
reported quantitative information on national PaMs did not improve, however,  for 
either  the  achieved  (ex-post),  expected  (ex-ante)  effects  on  GHG  emissions  and 
their  costs  and  benefits.  This  does  not  allow  for  a  comprehensive  analysis  of  the 
impacts  of  existing  national  climate  policies  across  the  EU  and  generates 
considerable uncertainty in comparing and summing up ex-post emission savings. 
Information on renewable energy production and energy savings, which had to be 
reported for the first time, was only anecdotally reported 95. 

The 2023 reporting shows the potential of this reporting as a repository for PaMs across all 
dimensions  of  the  Energy  Union,  although  there  is  still  room  for  improvement  on 
completeness96.  

The  technical  assessment  of  the  NECPRs  towards  meeting  the  EU’s  energy  and  climate 
objectives 97 found that 17 Member States reported indicators for at least one PaM. In total, 
750  indicators  (537  quantified)  were  reported  for  466  PaMs.  The  assessment  adds  that 
while ‘[i]deally, the reporting of indicators should include the indicator description with a 
unit, the years, and values [t]his is however not always provided, and often only qualitative 
information is reported, i.e. the description and a unit, without quantitative data’.  

B. Projections of anthropogenic GHG emissions by sources and removals by sinks 

Article  18(1)(b)  of  the  Governance  Regulation  and  Article  38  of  the  Implementing 
Regulation (EU) 2020/1208 set out the details for Member States to provide information 
on national GHG projections. From 2021, and then every two years, Member States are 
required to report GHG projections to the EU. The information to be reported is clustered 
into seven main areas (reporting tables) (see Figure 9).  

93  EEA,  Overview  of  national  reported  policies  and  measures  on  climate  change  mitigation  in  Europe  in  2019, 
Eionet, ETC/CME 5/2019, file:///C:/Users/gramu/Downloads/ETC_CME_Technical_Report_2019_5%20final.pdf  
94 EEA, Overview of national reported greenhouse gas policies and measures in Europe in 2021, Eionet, ETC/CME, 
5/2021, file:///C:/Users/gramu/Downloads/ETC-CME_EIONET_report_5-2021.pdf  
95  EEA,  Overview  of  national  reported  policies  and  measures  on  climate  change  mitigation  in  Europe  in  2019, 
Eionet, ETC/CME 5/2019, file:///C:/Users/gramu/Downloads/ETC_CME_Technical_Report_2019_5%20final.pdf  
96 Ibid.  
97 European Commission, Assessment of progress towards the objectives of the Energy Union and Climate Action, 
SWD(2023, 646 final, p. 62.  

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Figure 9.  Overview  of  reporting  tables  for  GHG  projections  and  related  information  in 
accordance with Article 18(1)(b) of the Governance Regulation and Article 38 of 
the Implementing Regulation (EU) 2020/1208 

Source:    EEA,  Trends  and  projections  under  the  Effort  Sharing  Legislation.  Overview  on 
developments and drivers, European Environment Information and Observation Network 
(Eionet), ETC/CME, 8/202, 2021, p. 5.  

Table 6 and Table 7 present the mandatory and optional reporting requirements. The main 
mandatory elements are98:  

  GHG projections  reported by gas (Total  GHGs, Total ETS GHGs, Total ESR  GHGs, 

CO2, CH4, N2O, HFC, PFC, SF6, NF3, unspecified mix of HFCs and PFCs);  

  Base year, 2020, 2025, 2030 and 2035, 2040;  
  Inventory version to which the GHG projections relate;  
  Split by sectors and categories in line with the common reporting format (CRF);  
  Detailed  LULUCF  projections,  including  projections  assigned  to  the  LULUCF 

accounting categories under the LULUCF Regulation;  

  Sectoral split into ETS and ESR emissions;  
  A WEM scenario - information on models;  
  Provision of a sensitivity analysis of the total GHG, ETS and ESR;  
  Underlying key parameters for the sensitivity analysis;  
  Provision of a description of methodologies, models, and underlying assumptions;  
  Provision of parameters and variables used in the projections. 

According  to  the  EEA  Eionet  report  in  2021,  the  completeness  of  reported  mandatory 
information  ‘has  not  changed  a  lot  for  most  Member  States  in  the  reporting  year  2021 
compared to 2019’ 99. All Member States submitted the mandatory WEM scenario (Table 1a 
in  Figure  9)  and  related  parameters.  However,  of  the  27  countries  that  provided 
projections, eight did not provide information on the sensitivity analysis: Cyprus, Denmark, 
Germany, Greece, Italy, Luxembourg, Slovakia and Spain100. Bulgaria did not submit model 
factsheets in 2021, and the Netherlands did not provide a specific report for projections or 

98  EEA,  Trends  and  projections  under  the  Effort  Sharing  Legislation.  Overview  on  developments  and  drivers, 
Eionet, ETC/CME, 8/202, 2021, p. 6.  
99 Ibid. p. 14.  
100 Ibid, p. 14. 

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a combined report for  projections and PaMs (Article 18(1) Governance Regulation). This 
represents an improvement on 2019 reporting (see Box 2).  

Box 2. 

Findings from EEA report 2021   

‘For  the  first  time  in  2021,  Member  States  were  required  to  provide  detailed  LULUCF 
projections. All Member States provided detailed LULUCF projections in either part 1 of 
Table 1b or in Table 5a. For the first time in 2021, information on emission and parameter 
sensitivity  scenarios  could  be  provided  in  Tables  6  and  7,  respectively.  Out  of  the  27 
Member States, 18 provided at least one scenario in both Tables 6 and 7 and 2 Member 
States  submitted  only  Table  6  (see  also  section  3.2).  The  completeness  of  voluntary 
information reported was substantially lower in 2021 compared to 2019. A total of 18 of 
the 27 Member States reported indicators in 2021. Regarding the scenarios, 22 Member 
States  reported  a  WAM  [with  additional  measures]  scenario,  and  only  four  reported  a 
WOM  scenario.  This  is  like  the  reporting  of  voluntary  information  in  2019,  when  17 
Member  States  reported  a  WAM  and  five  Member  States  reported  a  WOM  [without 
measures]  scenario’  (EEA,  Trends  and  projections  under  the  Effort  Sharing  Legislation. 
Overview on developments and drivers, Eionet, ETC/CME, 8/202, 2021, p. 14). 

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Table 6.  EEA comparative overview of completeness of projections reporting under Article 18(1)(b) of the Governance Regulation, 2017, 2019, 2021 

Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

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Member States  

Updated projections 

 Required sector split  

 Required GHG split  

 Provision of parameters  

 Sensitivity analysis 

 Model factsheet description 

2017  2019  2021 

  2017 

2019 

2021 

 2017  2019  2021 

  2017 

2019 

2021 

  2017  2019 

2021    2017 

2019 

2021 

AT 

BE 

BG 

HR 

CY 

CZ 

DK 

EE 

FI 

FR 

DE 

EL 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SK 

SI 

ES 

SE 

UK 

September, 2024 

Planned  

  Not used 

** 

** 

N/A 

N/A 

54 

N/A 

N/A 

N/A 

N/A 

 
 
 
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
  
 
   
 
   
 
   
 
   
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

Member States  

Updated projections 

 Required sector split  

 Required GHG split  

 Provision of parameters  

 Sensitivity analysis 

 Model factsheet description 

2017  2019  2021 

  2017 

2019 

2021 

 2017  2019  2021 

  2017 

2019 

2021 

  2017  2019 

2021    2017 

2019 

2021 

AT 

BE 

BG 

HR 

CY 

CZ 

DK 

EE 

FI 

FR 

DE 

EL 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SK 

SI 

ES 

SE 

UK 

Planned  

  Not used 

** 

N/A 

N/A 

N/A 

N/A 

** 

N/A 

N/A 

Yes, reported  

26  

27 

27 

  28 

27 

27 

  28 

27 

27 

  28 

27 

27 

  25 

23 

19 

  26 

26 

26 

September, 2024 

55 

 
 
 
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
  
 
   
 
   
 
   
 
   
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

Member States  

Updated projections 

 Required sector split  

 Required GHG split  

 Provision of parameters  

 Sensitivity analysis 

 Model factsheet description 

2017  2019  2021 

  2017 

2019 

2021 

 2017  2019  2021 

  2017 

2019 

2021 

  2017  2019 

2021    2017 

2019 

2021 

AT 

BE 

BG 

HR 

CY 

CZ 

DK 

EE 

FI 

FR 

DE 

EL 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SK 

SI 

ES 

SE 

UK 

Planned  

  Not used 

** 

N/A 

N/A 

N/A 

N/A 

** 

N/A 

N/A 

Not reported (mandatory reporting items) 

2 

1 

1 

1 

1 

  3 

3 

6 

  1 

2 

1 

September, 2024 

56 

 
 
 
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
  
 
   
 
   
 
   
 
   
 
 
 
   
 
   
 
   
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

Member States  

Updated projections 

 Required sector split  

 Required GHG split  

 Provision of parameters  

 Sensitivity analysis 

 Model factsheet description 

2017  2019  2021 

  2017 

2019 

2021 

 2017  2019  2021 

  2017 

2019 

2021 

  2017  2019 

2021    2017 

2019 

2021 

AT 

BE 

BG 

HR 

CY 

CZ 

DK 

EE 

FI 

FR 

DE 

EL 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SK 

SI 

ES 

SE 

UK 

Not reported but planned (mandatory reporting items) 

September, 2024 

Planned  

  Not used 

** 

** 

N/A 

2 

2 

N/A 

57 

N/A 

N/A 

N/A 

N/A 

 
 
 
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
  
 
   
 
   
 
   
 
   
 
 
 
 
 
   
 
 
   
 
 
   
 
 
   
   
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

Member States  

Updated projections 

 Required sector split  

 Required GHG split  

 Provision of parameters  

 Sensitivity analysis 

 Model factsheet description 

2017  2019  2021 

  2017 

2019 

2021 

 2017  2019  2021 

  2017 

2019 

2021 

  2017  2019 

2021    2017 

2019 

2021 

AT 

BE 

BG 

HR 

CY 

CZ 

DK 

EE 

FI 

FR 

DE 

EL 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SK 

SI 

ES 

SE 

UK 

Not reported (voluntary reporting items) 

September, 2024 

Planned  

  Not used 

** 

** 

N/A 

  1 

N/A 

58 

N/A 

N/A 

N/A 

N/A 

 
 
 
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
  
 
   
 
   
 
   
 
   
 
 
 
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

Member States  

Updated projections 

 Required sector split  

 Required GHG split  

 Provision of parameters  

 Sensitivity analysis 

 Model factsheet description 

2017  2019  2021 

  2017 

2019 

2021 

 2017  2019  2021 

  2017 

2019 

2021 

  2017  2019 

2021    2017 

2019 

2021 

AT 

BE 

BG 

HR 

CY 

CZ 

DK 

EE 

FI 

FR 

DE 

EL 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SK 

SI 

ES 

SE 

UK 

 * Reported in PaM folder 

September, 2024 

Planned  

  Not used 

** 

** 

N/A 

N/A 

59 

N/A 

N/A 

N/A 

N/A 

 
 
 
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
  
 
   
 
   
 
   
 
   
 
 
 
 
 
   
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

Member States  

Updated projections 

 Required sector split  

 Required GHG split  

 Provision of parameters  

 Sensitivity analysis 

 Model factsheet description 

2017  2019  2021 

  2017 

2019 

2021 

 2017  2019  2021 

  2017 

2019 

2021 

  2017  2019 

2021    2017 

2019 

2021 

AT 

BE 

BG 

HR 

CY 

CZ 

DK 

EE 

FI 

FR 

DE 

EL 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SK 

SI 

ES 

SE 

UK 

** Only table 6 was submitted  

September, 2024 

Planned  

  Not used 

** 

** 

N/A 

N/A 

60 

N/A 

N/A 

N/A 

N/A 

 
 
 
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
  
 
 
   
 
 
   
 
 
   
 
   
 
 
 
 
 
  
 
   
 
   
 
   
 
   
 
 
Table 7.  EEA comparative overview of completeness of projections reporting under Article 18(1)(b) of the Governance Regulation, 2017, 2019, 2021 

Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

September, 2024 

61 

 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

Member States 

Scenarios  

Report 

Provision 
indicators  

of 

Reporting  of 
year 2040 

the 

Detailed 
projections  

LULUCF 

LULUCF 
projections  

accounted 

WEM  

 WAM 

 WOM  

2017  2019  2021   2017  2019  2021   2017  2019  2021  2017  2019  2021  2017  2019  2021  2017 

2019 

2021 

2021 

AT 

BE 

BG 

HR 

CY 

CZ 

DK 

EE 

FI 

FR 

DE 

EL 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SK 

SI 

ES 

* 

* 

* 

* 

* 

September, 2024 

62 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

SE 

UK 

N/A 

N/A 

N/A 

Yes, reported  

28 

27 

27 

 16 

16 

22 

 5 

3 

4 

27 

27 

26 

8 

6 

18 

4 

14 

27 

27 

Not reported (mandatory reporting 
items) 

1 

1 

1 

Not 
(mandatory reporting items) 

reported 

but 

planned 

Not  reported  (voluntary  reporting 
items) 

* Reported in PaM folder 

** Only table 6 was submitted  

1 

 11 

11 

5 

 22 

24 

23 

19 

21 

9 

24 

13 

September, 2024 

63 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the 
Energy Union and Climate Action 

Annual reporting (Article 26 of the Governance Regulation) 

According  to  Article  26  of  the  Governance  Regulation,  the  European  Commission  shall 
annually compile a Union approximated GHG inventory. This should be based on Member 
States'  approximated  GHG  inventories  or  based  on  estimates  made  by  the  European 
Commission  itself  if  the  inventories  are  not  submitted  to  the  European  Commission  on 
time.  It  also  foresees  that  the  Commission,  in  cooperation  with  Member  States,  shall 
compile an annual Union GHG inventory report to be submitted to the UNFCCC Secretariat 
by 15 April each year.  

The EU, as part of the UNFCCC, reports annually on GHG inventories for the years between 
1990  and  the  calendar  year  of  submission  minus  two  years  (t-2)  for  emissions  and 
removals taking place within the territory of the Member States.    

Reporting on the 2020 targets (Article 27 of the Governance Regulation) 

Article 27 of the Governance Regulation sets out rules on ‘Reporting on the 2020 targets’. 
More specifically, it establishes that by 30 April 2022, each Member State shall report to 
the  Commission  on  the  achievement  of  its  2020  energy  efficiency  national  target 
established pursuant to Article 3(1) of the EED, by providing the information set out in Part 
2  of  Annex  IX  to  the  Governance  Regulation,  as  well  as  overall  national  targets  for  the 
share of energy from renewable sources in 2020, as set out in Annex I to the RED in the 
version in force on 31 December 2020, by providing information on:  

  Sectoral  (electricity,  heating  and  cooling,  and  transport)  and  overall  shares  of 

energy from renewable sources in 2020;  

  Measures taken to achieve the 2020 national renewable energy targets, including 
measures  related  to  support  schemes,  guarantees  of  origin  and  simplification  of 
administrative procedures;  

  Share of energy from biofuels and bioliquids produced from cereal and other starch-

rich crops, sugars and oil crops in energy consumption in transport;  

  Share  of  energy from biofuels and biogas  for transport produced from feedstocks 
and of other fuels listed in Part A of Annex IX to the RED in the version in force on 
31 December 2020 in energy consumption in transport. 

In  2002,  the  Joint  Research  Centre  (JRC)  published  its  ‘Analysis  of  the  reports  on  2020 
targets under Article 27 of the Governance Regulation – energy efficiency’ (see Box 3 for 
main findings).  

September, 2024 

64 

 
 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the 
Energy Union and Climate Action 

Box 3. 

Analysis  of  the  reports  on  2020  targets  under  Article  27  of  the  Governance 
Regulation – energy efficiency (JRC, 2022)   

In 2020, both PEC and  FEC targets were achieved, influenced by COVID-19 and  related 
lockdowns.  

The energy savings obligations under Article 5 (Exemplary role of public bodies’ buildings) 
and Article 7 (Energy efficiency obligation schemes) of the EED were crucial. The JRC report 
noted good progress in the implementation of Article 7 and Article 5. However, there is still 
a  lack  of  information  provided  in  the  2020  target  reports,  with  some  gaps  in 
information,  corresponding  to  similar  gaps  in  previous  years.  Nevertheless,  the  JRC 
analysis  suggests  that  the  Article  7  target  was  achieved  at  EU  level  in  2020,  while  the 
cumulative target for 2014-2020 was 98 % achieved. The different approaches in reporting 
between the Member States prevent an understanding of their level of target achievement, 
but most appeared to achieve either the annual obligation in 2020 or the 2014-2020 total 
obligation. Some Member States included ‘new’ measures in their 2020 target reports to 
accelerate their efforts to achieve the 2020 targets.  

Twenty-four Member States reached the national targets set under Article 3 of the EED on 
PEC, while 21 achieved the targets for FEC.  

The JRC emphasised the importance of using a CRF. The template introduced in 2015 and 
fine-tuned  in  2016/2017  allowed  Member  States  to  harmonise  the  collection  of  main 
information  and  well-defined 
indicators,  avoiding  serious  misinterpretations  and 
subsequent need of requests for clarification (JRC, Analysis of the reports on 2020 targets 
under Article 27 of the Governance Regulation – energy efficiency, 2022, p. 42). 

Increased timeliness of information  

Different  stakeholder  groups  hold  varying  opinions  on  the  timeliness  of 
information  provision.  Most  Member  State  authorities  claimed  that  the 
Governance  Regulation  has  significantly  helped  to  complete  their  planning  and 
reporting on time, while third sector and industry stakeholders tended to indicate 
that this was not the case.  

Figure 10 presents a rather fragmented picture. Across all stakeholders, the most common 
response was that the Governance Regulation had helped Member States to complete their 
obligations and provide information on time ‘only to a small extent’ (28 % of all responses) 
–  this  was  the  dominant  view  among  third-sector  respondents  (37 %)  and  industry 
representatives  (27 %).  A  majority  (57 %)  of  national  authorities  found  that  the 
Governance  Regulation  had  contributed  to  better  timeliness  at  least  ‘to  some  extent’, 
although  about  one-third  (30 %)  answered  less  positively.  Only  7 %  of  all  respondents 
found that the Governance Regulation had not improved timeliness at all101.  

101 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 NCAs and industry stakeholders were only asked about 
their Member States meeting reporting and planning obligations on time.  

September, 2024 

65 

 
 
 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the 
Energy Union and Climate Action 

Figure 10. Stakeholders’ views on planning and reporting timeliness 

Source: ICF, based on targeted surveys. 

Most  national  authorities  that  responded  to  the  survey  indicated  that  the  Governance 
Regulation had helped their Member State to complete planning and reporting on time 102. 
Some,  however,  disagreed.  For  example,  one  pointed  out  that  while  for  some  reporting 
obligations the reporting was streamlined, the new reporting obligations for NECPRs had 
delayed reporting on PaMs103. Similarly, another national authority stressed that the new 
indicators required under the Governance Regulation created pressure in Member States 
with small public administrations, as the same experts are involved in both planning and 
reporting (parallel processes), reducing the likelihood of completing them on time 104.  

A  Danish  national  authority  noted  that  the  Danish  Climate  Law  (2018),  the  governing 
energy and climate planning tool, contains specific deadlines for national reporting, thus 
the Governance Regulation has not influenced the timeliness of information provision 105.  

Finally, a German national authority pointed out that coordination at national level among 
different  authorities  has  had  a  greater  impact  on  the  timeliness  of  the  planning  and 
reporting than the requirements of the Governance Regulation 106. This could be considered 
an  external  factor  influencing  the  effectiveness  of  the  timeliness  of  the  planning  and 
reporting under the Governance Regulation. Similarly, Belgian national authorities pointed 
out that their internal process of data collection for long-term scenarios and the fact that 
there  was  no  alignment  in  the  national  reporting  system  and  the  reporting  obligations, 
created challenges in fulfilling the deadlines laid down in the Governance Regulation.  

102 Targeted survey for NCAs (Q3.4, N=30): 7/30 ‘to a large extent’; 7/30 ‘to some extent’; 7/30 ‘only to a small 
extent’. 
103 Open-text response to Q3.4 – targeted survey for NCAs (1).  
104 Open-text response to Q3.4 – targeted survey for NCAs (1).  
105 Open-text response to Q3.4 – targeted survey for NCAs (1).  
106 Interview with NCA (Germany). The authority pointed out that reporting every two years is challenging (4-6 
years would be a normal reporting cycle nationally). In Germany, 15 different ministries have to agree to the 
reports, making it difficult in the short timeframe provided.   

September, 2024 

66 

 
 
 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the 
Energy Union and Climate Action 

According to the industry stakeholders surveyed, the Governance Regulation has helped 
national  authorities  to  meet  planning  and  reporting  obligations  in  a  timely  manner  to  a 
limited  extent107.  Similarly,  third  sector  stakeholders  indicated  that  the  Governance 
Regulation has made it easier to access data in a timely manner only to a limited extent 108. 
Overall, in the interviews, third sector stakeholders stressed that the timing of the planning 
and reporting depends significantly on the individual Member State, with some delivering 
on time and others with delays109. One third sector organisation clarified that the delays 
indicate  problems  at  the  level  of  implementation  by  Member  States,  and  are  not 
attributable directly to the Governance Regulation 110. 

NECPs  

The  evaluation  found  that  the  timeliness  of  the  submission  of  the  draft  NECPs 
was  not  always  assured.  Nevertheless,  the  extent  to  which  this  problem  is 
directly  linked  to  the  Governance  Regulation,  or  results  from  practices  and/or 
procedural bottlenecks at Member State level, is unclear. 

Article  3(1)  of  the  Governance  Regulation  establishes  that  by  31  December  2019,  and 
subsequently by 1 January 2029 and every 10 years thereafter, each Member State shall 
notify an integrated NECP to the Commission.  

Evidence shows that there were difficulties with the timely submission of draft NECPs 111. 
The  2020  EU-wide  assessment  of  the  final  NECPs  ascertained  that  although  all  Member 
States submitted their final plans, some were delayed112.  

On  18  December  2023,  the  Commission  published  its  EU-wide  assessment  of  the  draft 
updated  NECPs,  together  with  country-specific  assessments  and  CSRs  for  21  Member 
States, guiding them towards final updated NECPs that can deliver the most recent climate 
and energy objectives and targets resulting from the Fit for 55 package and REPowerEU. 
The  Commission  stressed  that  ‘[w]hile  most  of  the  Member  States  have  now  submitted 
their draft updated plans, the Commission regrets the significant delay in the submission 
of  several  draft  plans  which  has  significantly  compromised  the  process  and  calls  on  all 
Member States to respect the deadline for the submission of the final plans in June 2024’. 
As of December 2023, only 21 Member States had submitted their revised plans113, with 
the remaining six Member States failing to do so114.  

Five  respondents  to  the  CfE  (representing  NGOs  and  industry)  underlined  problems 
associated  with  the  timely  submission  of  NECPs115.  According  to  one  NGO,  the  late 

107 Targeted survey for industry (Q6.4, N=15): 4/15 respondents ‘only to a small extent’; 4/15 ‘Do not know/Not 
applicable’; 3/15 ‘to some extent’.  
108  Targeted  survey  for  third  sector  (Q6.5,  N=19):  7/19  respondents  ‘only  to  a  small  extent’;  6/19  ‘to  some 
extent’. 
109 Interviews with third sector organisations (3).  
110 Interview with third sector organisation (1).  
111 Oberthür et al., Towards and EU Climate Governance Framework to Deliver on the European Green Deal, Policy 
paper,  2023,  https://brussels-school.be/sites/default/files/documents/Policy  options  paper  EU  Climate 
Governance Framework 2023-compressed.pdf   
112 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee  and  the Committee  of  the  Regions,  An  EU-wide  assessment  of  National  Energy  and Climate 
Plans:  Driving  forward  the  green  transition  and  promoting  economic  recovery  through  integrated  energy  and 
climate 
https://eur-lex.europa.eu/legal-
564 
content/EN/TXT/PDF/?uri=CELEX:52020DC0564  
113 CY, CZ, DE, DK, EE, EL, ES, FI, FR, HR, HU, IT, LT, LU, MT, NL, PT, RO, SE, SI, SK.  
114  As  of  December  2023:  draft  updated  NECP  of  Belgium  was  submitted  on  30  November  2023;  Ireland  and 
Latvia,  both  submitted  on  8  December  2023;  Austria,  Bulgaria  and  Poland  had  not  yet  submitted  their  draft 
updated NECP.  
115  Replies  to  CfE:  NGOs  (3)  Youth  and  Environment  Europe;  CAN  Europe,  Transport  and  Environment. 
Environmental organisation: WWF European Policy Office. Business association: EAE; European Association for 
External Thermal Insulation Composite Systems (ETICS).  

COM(2020) 

planning, 

final, 

September, 2024 

67 

 
 
 
 
 
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Energy Union and Climate Action 

submission of NECPs is a widespread practice among Member States116. According to two 
stakeholders  consulted,  one  factor  that  may  have  hampered  the  timely  submission  of 
NECPs  (and  NECPRs)  was  the  lack  of  alignment  between  the  Governance  Regulation 
timeframe/deadlines  and  other  national-level  cycles  for  the  adoption  of  local/national 
plans117.  One  underlined  that  the  timely  submission  of  information  is  highly  context-
specific. According to  one public authority, the timeframe for submitting the NECPs was 
‘excessively  short’,  considering  the  extensive  nature  of  the  data  to  be  gathered  and  its 
diverse  sources 118.  Finally,  two  national  authorities  underlined  problems  with  the  short 
timeframe between the NECPRs and draft NECPs, with one noting that the short timeframe 
makes it difficult to adequately incorporate the lessons of the NECPRs119. 

At the stakeholder event organised by the Commission, participants were asked to indicate 
the main prerequisites for, and barriers to, the timely submission of NECPs/NECPRs and 
their  completeness/quality.  One  national  authority  clarified  that  the  time  for  the 
preparation of the NECP was not sufficient, given the late publication of the guidance from 
the  Commission  and  the  multiple  dimensions  to  report  against,  as  well  as  the  technical 
difficulties of the reporting systems. Another national authority focused on constraints in 
administrative  capacity  to  comply  with  the  reporting  requirements  of  the  Governance 
Regulation, such as insufficient human resources (staff), complexity of the reporting tasks, 
and  their  requirements  (e.g.  in  parallel,  there  are  several  reports  to  the  UN).  Another 
national authority echoed this view and stressed that it was difficult to update the NECP 
on time, considering its numerous sections.  

LTSs 

The evidence showed significant delays in the submission of LTSs, creating delays 
and inefficiencies in the Commission’s EU-wide assessment of the LTSs. There are 
indications that the lack of timeliness in the submission of LTSs derives from insufficient 
national  administrative  capacity  to  fulfil  the  reporting  obligations  under  the  Governance 
Regulation and the sequencing of the planning and reporting obligations (e.g. final NECPs 
deadline of 31 December 2019 was very close to the LTSs deadline of 1 January 2020).  

Article  15(1)  of  the  Governance  Regulation  requires  each  Member  State  to  prepare  and 
submit,  by  1  January  2020,  and  subsequently  by  1  January  2029  and  every  10  years 
thereafter,  to  the  Commission  its  LTS  with  a  perspective  of  at  least  30  years.  Where 
necessary, Member States should update those strategies every five years.  

116 Replies to CfE: Youth and Environment Europe. 
117 Scoping interviews with EU institution and NCA. 
118 Reply to CfE: Public authority from ES, Ministry for the Ecological Transition and the Demographic Challenge. 
119 Ibid. 

September, 2024 

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Energy Union and Climate Action 

Source:  Velten,  E.K.,  Evans,  N.,  Spasova,  D.,  Duwe,  M.,  de  la  Vega,  R.,  Duin,  L.  and 
Branner, H., Charting a path to net zero: An assessment of national long-term strategies 
in the EU, Ecologic Institute, Berlin, 2022, p. 59. 

On the timeliness of the submission of LTSs, a study from the Ecologic Institute120 showed 
that  only  nine  strategies  were  delivered  by  the  1  January  2020  deadline,  although  the 
Greek  and  Lithuanian  strategies  were  submitted  shortly  after.  Four  Member  States 
(Belgium, Finland, France, Slovakia) submitted their LTSs in the first quarter of 2020. Italy, 
Slovenia and Spain, among others, did not produce a strategy until months or over a year 
after the initial submission date, while Hungary, Luxembourg and Malta were more than 
18 months late submitting their LTSs. As of February 2024, one Member State (Poland) 
has yet to submit its LTS121.  

The Ecologic Institute study found that ‘the lack of capacities and technical know-how for 
scenario  development  was  a  common  bottleneck,  especially  considering  the  need  to 
produce  both  the  NECP  and  LTS  more  or  less  simultaneously’122.  This  delayed  the 
Commission in producing its EU-wide assessment of the LTSs. 

At the stakeholder event, the Ecologic Institute commented that the timing of the processes 
for NECPs and LTSs puts the first NECP deadline before the LTS, constituting a shortcoming 
for  the  overall  planning  process.  Two  NGOs  that  replied  to  the  CfE  reported  that  many 
Member States see the development of LTSs as a procedural requirement that might be 
postponed, rather than a much-needed, long-term planning tool123. 

This evaluation finds that Member State authorities may still lack administrative capacity 
to  deliver  the  sets  of  planning  and  reporting  requirements  laid  down  in  the  Governance 
Regulation, including the LTS.  

120 Velten, E.K., Evans, N., Spasova, D., Duwe, M., de la Vega, R., Duin, L. and Branner, H., Charting a path to 
net zero: An assessment of national long-term strategies in the EU, Ecologic Institute, Berlin, 2022, p. 59. 
121  Poland,  as  per  the  European  Commission  website  (https://commission.europa.eu/energy-climate-change-
environment/implementation-eu-countries/energy-and-climate-governance-and-reporting/national-long-term-
strategies_en). 
122 Ibid.  
123  Replies  to CfE: NGO:  CAN  Europe.  Environmental  Organisation:  WWF  European  Policy Office; CAN  Europe, 
Getting the long-term planning right. The role of National Long-Term strategies in achieving climate neutrality in 
Europe, 2021, https://unify.caneurope.org/wp-content/uploads/sites/2/2021/12/raport-can-23-12-prev-1.pdf  

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Energy Union and Climate Action 

Biennial progress reports and their follow up (NECPRs and reporting obligations stemming 
from Article 17 of the Governance Regulation) 

The  evaluation  finds  that  the  biennial  progress  reports  and  their  follow  up 
(NECPRs and reporting obligations stemming from Article 17 of the Governance 
Regulation)  were  submitted  either  on  time  or  with  a  small  delay,  thus  not 
impacting the effectiveness of the Governance Regulation.  

Article 17 of the Governance Regulation requires each Member State, by 15 March 2023, 
and  every  two  years  thereafter,  to  report  to  the  Commission  on  the  status  of 
implementation of its integrated NECP by means of an integrated NECPR covering all five 
dimensions  of  the  Energy  Union.  According  to  the  Commission’s  October  2023  technical 
assessment of the NECP progress reports, ‘8 Member States submitted a prima facie full 
progress report by the 15 March deadline, and 10 more submitted their progress report 
relatively close to the deadline’124.  

At the stakeholder event, two national authorities noted the large volume of information 
that  must  be  provided,  with  some  requiring  regular  updates  in  the  progress  reports, 
imposing a burden on administrators125. 

Integrated  reporting  on  GHG  PaMs  and  projections  (Article  18)  –  a)  PaMs,  and  b) 
Projections of anthropogenic GHG emissions by sources and removals by sinks 

The timeliness of information on PaMs remained stable between 2017 and 2019, 
improved  in  2021,  then  deteriorated  in  2023.  Information  on  projections  of 
anthropogenic  GHG  emissions  by  sources  and  removals  by  sinks  improved  in 
2019 compared to 2017, and deteriorated in 2021. Nevertheless, the evaluation 
does  not  find  a  lack  of  effectiveness  that  can  be  attributed  to  the  Governance 
Regulation.  

Article 18 of the Governance Regulation requires Member States to report, by 15 March 
2021, and every two years thereafter, to the Commission information on: (a) their national 
PaMs or group of measures as set out in Annex VI; and (b) their national projections of 
anthropogenic GHG emissions by sources and removals by sinks.  

Table 5.8 shows that timeliness  of submissions  on  PaMs  remained  stable between 2017 
(under the MMR) and 2019 (with nine Member States meeting the deadline, and 19 falling 
short).  The  timeliness  of  the  reported  information  improved  in  2021,  with  15  Member 
States  meeting  the  deadline  (12  did  not).  In  2023,  the  timeliness  of  submissions 
deteriorated, with 16 Member States failing to meet the deadline.  

Table 8.  Timeliness of submissions (PaMs) 

Number of Member States meeting/missing the deadline 

2017 

9 

19 

2019 

2021 

2023 

9  

19 

15 

12 

11 

16 

Source: ICF, based on EEA reports 2017-2023. 

The table below provides a breakdown per Member State, where available.  

124 European Commission, Assessment of progress towards the objectives of the Energy Union and Climate Action, 
SWD(2023, 646 final, p. 3.  
125 Stakeholder workshops – remarks from NCAs (2). 

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Energy Union and Climate Action 

Table 9.  Timeliness of submissions (PaMs) per Member State  

Member 
State 

2017  

2019 

2021 

2023 

FI 

RO 

DK 

BG 

EE 

HR 

SI 

NL 

SE 

MT 

PT 

Breakdown  per 
national 
authority  

Breakdown  per 
national 
authority 

Breakdown  per 
national 
authority  

Breakdown  per 
national 
authority 

Breakdown  per 
national 
authority 

Breakdown  per 
national 
authority 

Breakdown  per 
national 
authority 

Breakdown 
per 
national 
authority 

Breakdown 
per 
national 
authority 

Breakdown 
per 
national 
authority 

Breakdown 
per 
national 
authority 

Breakdown 
per 
national 
authority 

Breakdown 
per 
national 
authority 

Breakdown 
per 
national 
authority  

Breakdown  per 
MS NA 

Breakdown 
per MS NA 

Breakdown  per 
national 
authority 

Breakdown  per 
national 
authority  

Breakdown  per 
national 
authority  

Breakdown 
per 
national 
authority 

Breakdown 
per 
national 
authority 

Breakdown 
per 

September, 2024 

71 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Energy Union and Climate Action 

Member 
State 

2017  

2019 

2021 

2023 

ES 

CY 

LV 

EL 

IE 

IT 

SK 

FR 

AT 

CZ 

Breakdown  per 
national 
authority 

Breakdown  per 
national 
authority 

Breakdown  per 
national 
authority 

Breakdown  per 
national 
authority  

Breakdown  per 
national 
authority 

Breakdown  per 
national 
authority 

Breakdown  per 
national 
authority 

Breakdown  per 
national 
authority 

Breakdown  per 
national 
authority  

Breakdown  per 
national 
authority  

national 
authority 

Breakdown 
per 
national 
authority 

Breakdown 
per 
national 
authority 

Breakdown 
per 
national 
authority 

Breakdown 
per 
national 
authority 

Breakdown 
per 
national 
authority 

Breakdown 
per 
national 
authority 

Breakdown 
per MS NA 

Breakdown 
per 
national 
authority  

Breakdown 
per 
national 
authority  

Breakdown 
per 
national 
authority  

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72 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Energy Union and Climate Action 

Member 
State 

HU 

BE 

LU 

DE 

PL 

LT 

2017  

2019 

2021 

2023 

Breakdown  per 
national 
authority  

Breakdown  per 
national 
authority  

Breakdown  per 
national 
authority  

Breakdown  per 
national 
authority  

Breakdown  per 
national 
authority  

Breakdown  per 
national 
authority  

Breakdown 
per 
national 
authority  

Breakdown 
per 
national 
authority  

Breakdown 
per 
national 
authority  

Breakdown 
per 
national 
authority  

Breakdown 
per 
national 
authority  

Breakdown 
per 
national 
authority  

Source: ICF, based on EEA reports 2017-2023.  

Note: red cells=information submitted late; green cells=information submitted on time. 

While  information  from  previous  reporting  could  be  reused,  the  2023  submission 
required  more  extensive  integrated  reporting  on  the  five  climate  and  energy 
dimensions, as well as on new annexes. According to the European Court of Auditors 
(ECA),  this  could  have  contributed  to  the  delay  in  submissions126.  In  addition,  the  new 
webform in Reportnet demanded more learning time on data input. Another explanation 
for delayed reporting is the preference to link reporting of both GHG projections and PaMs. 
By the end of June 2023, Member States had to report a draft updated NECP, which, in 
some countries, may have impacted the political process of submitting data under these 
annexes.  Given  the  more  extensive  reporting,  the  subsequent  QA/QC  process  also  took 
more time in 2023.  

EEA  reports  illustrate  that  in  2019,  16  Member  States127  submitted  their  projections  of 
anthropogenic GHG emissions by sources and removals by sinks, before or on the official 
deadline  of  15  March  2019.  This  was  a  slight  improvement  on  2017,  when  13  Member 
States had reported their projections by 15 March. Ten Member States128 submitted within 

126 EEA, Overview of national reported policies and measures on climate change mitigation in Europe in 2019, 
Eionet, ETC/CME 5/2019, file:///C:/Users/gramu/Downloads/ETC_CME_Technical_Report_2019_5%20final.pdf  
127 AT, BE, BG, CZ, EE, ES, HR, IE, IT, LV, NL, PL, SE, SI, SK and UK.  
128 DE, DK, EL, FI, FR, HU, LT, LU, MT, PT.   

September, 2024 

73 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Energy Union and Climate Action 

six weeks of the deadline (compared to nine in 2017). Bulgaria and Cyprus submitted 61 
and 73 days after the deadline, with Cyprus the last EU Member State to submit (end of 
May).  Romania  did  not  submit  projections  in  2019.  Thirteen  Member  States  submitted 
earlier  in  2019,  but  three  did  not  meet  the  reporting  deadline  despite  improving  their 
timeliness (Greece, Hungary, Malta) (see Table 10). Eight countries submitted later in 2019 
than in 2017 and none achieved a timely submission before the deadline: Bulgaria, Cyprus, 
Denmark, Finland, France, Germany, Luxembourg, Portugal129.  

Table 10.  Timeliness  of  information  on  projections  of  anthropogenic  GHG  emissions  by 

sources and removals by sinks 

Number of Member States meeting/missing the deadline 

2017 

13 

15 

2019 

16  

11 

2021 

12 

15 

Source: ICF, based on EEA reports 2017-2021. 

In 2021, 12 Member States130 submitted their projections before or on the official deadline 
of 15 March 2021, a deterioration  compared to 2019, when 16 Member States  reported 
their projections by the deadline. Seven Member States131 submitted within six weeks of 
the deadline (10 in 2019). Eight Member States submitted even later (Cyprus, Denmark, 
France, Hungary, Luxembourg, Slovakia, Slovenia). Overall, six Member States submitted 
earlier  in  2021  compared  to  2019  (Bulgaria,  Finland,  Greece,  Malta,  Poland,  Portugal), 
while 16 submitted later. Four Member States submitted on the same date in both years 
(Austria, Croatia, Czechia, Estonia)132. 

Annual report (Article 26 of the Governance Regulation)  

As the EU GHG inventory is compiled based on the inventories of EU Member States, both 
the  completeness  and  the  timeliness  of  the  information  depends  on  Member  States’ 
submissions.  

To ensure that the European Commission can respect the deadline of 15 April to submit its 
report to the UNFCCC, the final submission for Member States of national inventory reports 
is set on 15 March each year. Table 11 shows the evolution of the timeliness of Member 
States’ submissions from 2017 to 2023 for the compilation of the EU GHG inventory.  

Table 11.  Summary  of  timeliness  of  Member  States’  national  GHG  inventory  report 

submissions, 2017-2023 

Memb
er 
State 

AT 

2017 

2018 

2019 

2020 

2021 

2022 

2023 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

129 EEA, Analysis of Member States’ 2019 GHG projections, Eionet, ETC/CME 2019/6, p. 17.  
130 AT, CZ, EE, ES, FI, HR, IT, MT, NL, PL, PT, RO.  
131 BE, BG, EL, IE, LT, LV, SE.   
132  EEA,  Trends  and  projections  under  the  Effort  Sharing  Legislation.  Overview  on  developments  and  drivers, 
Eionet, ETC/CME, 8/202, 2021, p. 13.  

September, 2024 

74 

 
 
 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the 
Energy Union and Climate Action 

Memb
er 
State 

BE 

BG 

CY 

CZ 

DE 

DK 

ES 

EE 

FI 

FR 

UK 

EL 

HR 

2017 

2018 

2019 

2020 

2021 

2022 

2023 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Submissio
n on time 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Submissio
n on time 

Submissio
n on time 

Submissio
n on time 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Submissio
n on time 

Submissio
n on time 

Submissio
n on time 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Submissio
n on time 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

UK: 
Submissio
n on time 

UK:  Late 
submissio
n 

N/A 

N/A 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Submissio
n on time 

Submissio
n on time 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

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Energy Union and Climate Action 

Memb
er 
State 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

2017 

2018 

2019 

2020 

2021 

2022 

2023 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Submissio
n on time 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Submissio
n on time 

Submissio
n on time 

Submissio
n on time 

RO 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

SK 

SI 

Submissio
n on time 

Late 
submissio
n 

Submissio
n on time 

Submissio
n on time 

Submissio
n on time 

Late 
submissio
n 

Submissio
n on time 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

September, 2024 

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Energy Union and Climate Action 

Memb
er 
State 

SE 

2017 

2018 

2019 

2020 

2021 

2022 

2023 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Submissio
n on time 

Submissio
n on time 

Submissio
n on time 

Submissio
n on time 

EU133  On  time: 
7 

On  time: 
0  

On  time: 
6  

On  time: 
7  

On  time: 
8  

On  time: 
7  

On  time: 
25  

Late 
submissi
on: 21  

Late 
submissi
on: 28  

Late 
submissi
on: 22  

Late 
submissi
on: 21  

Late 
submissi
on: 20  

Late 
submissi
on: 20  

Late 
submissi
on: 

IS 

Late 
submissio
n 

Late 
submissio
n 

Submissio
n on time 

Late 
submissio
n 

Late 
submissio
n 

Late 
submissio
n 

2  

/ 

UK 

N/A 

N/A 

N/A 

N/A 

N/A 

/ 

Late 
submissio
n 

Source: ICF, based on annual EU GHG inventory 1990-2021 and inventory reports, 2017 to 2023. 

Table 11 shows that for almost all years considered, most of the Member States did not 
submit  the  national  inventory  report  by  the  15  March  deadline.  The  number  of  Member 
States that met the deadline remained  steady over the  years, with six to  eight Member 
States,  on  average,  submitting  on  time,  apart  from  2018,  when  no  Member  State 
submitted the report by 15 March. Some delays were limited to a few days, but several 
were  a  month  or  more.  The  situation  changed  dramatically  in  2023,  when  almost  all 
Member  States  met  the  submission  deadline.  The  two  Member  States  that  missed  the 
deadline submitted their national report within one to two days, with only minimal impact 
on the ability of the European Commission to compile the EU GHG inventory report on time 
and using actual data.  The  years ahead will tell whether  or not this is a lasting positive 
trend.  

Increased (public) accessibility of reported information  

The  Governance  Regulation  has  increased  (public)  accessibility  of  reported 
information somewhat. Stakeholders have divergent views and highlighted areas 
where the public accessibility of reported information proved limited. However, 
it remains unclear whether these issues are linked to the Governance Regulation, 
or, more likely, to implementation issues and/or national traditions.  

The Governance Regulation provides that Member States must make available to the public 
their NECPs, NECPRs, and respective LTSs (Article 17(7), Article 15(7)). As per Article 28, 
the Commission established an online platform to facilitate communication with Member 
States,  promote  cooperation  among  Member  States,  and  facilitate  public  access  to 
information.  Member  States  must  use  this  platform  for  the  purpose  of  submitting  the 
relevant reports to the Commission (Article 28(2) Governance Regulation). 

133 EU-28: 2017; 2018; 2019; 2020; 2021. EU-27: 2022; 2023. 

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As shown in Figure 11, two-thirds (68 %)  of stakeholders believed that the Governance 
Regulation has contributed to heightened data accessibility for the public, including 30 % 
who thought it had done so ‘to a (very) large extent’.  

Figure 11. Stakeholders’ views on public accessibility of planning and reported data 

Source: ICF, based on targeted surveys. 

Most of the national authorities highlighted that the data in their national plans and reports 
have  become  somewhat  more  accessible  to  the  public  because  of  the  Governance 
Regulation134.  Nevertheless, the  evidence  suggests that the accessibility  of the reported 
information  still  relies  heavily  on  the  different  traditions  of  the  Member  States.  Spanish 
national authorities, for instance, pointed out that it is difficult for the public to access the 
reporting platforms or the EU information repository. 

Echoing  this,  national  authorities  from  Germany  stressed  that  the  current  and  complex 
reporting  formats  are  not  very  accessible  beyond  the  reporting  community,  as  the 
Governance  Regulation  does  not  provide  standardised  requirements  that  would  require 
Member States to make the reported information more accessible135. 

Most  third  sector  stakeholders 136  and  nearly  half  of  the  industry  representatives 137 
indicated  that  the  Governance  Regulation  has  somewhat  enhanced  access  to  the 

134 Targeted survey for NCAs (Q3.5, N=30): 12/30 ‘to some extent’, 8/30 ‘to a large extent’; 3/30 ‘to a very large 
extent’.  
135 Open-text response to Q3.5 – targeted survey for NCAs (Germany). German NCAs pointed out the need to 
differentiate  between  different  target  groups  because  interested  citizens,  scientists,  companies,  public 
administrations  etc.  need  different  types  of  information  preparation.  Consequently,  ensuring  accessibility  is 
capacity-intensive and demanding task. 
136 Targeted survey for third sector (Q6.4, N=19): 13/19 ‘to some extent’; 3/16 ‘only to a small extent; 2/19 ‘to 
a very large extent’.  
137 Targeted survey for industry (Q6.5, N=16): 6/16 ‘to some extent’; 3/16 ‘to a large extent’; 3/30 ‘only to a 
small extent’.  

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information in Member States plans and reports. However, one third sector organisation 
stressed that access to information remains unsatisfactory for young people138.  

Finally,  nine  respondents  to  the  CfE  reported  that  transparency  and  availability  of 
information  underpinning  the  NECPs  is  insufficient139.  One  NGO140  explained  that  NECPs 
and  NECPRs  are  not  always  published  in  full  or  are  published  late  by  the  European 
Commission (due to delays from Member States), preventing informed participation of the 
public. Another NGO underlined that all stakeholders should be able to easily monitor the 
data included by Member States in their NECPRs – this has not been ensured so far141.  

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

The  Governance  Regulation  has  been  effective  in  promoting  better  planning 
processes.  The  national  authorities  agreed  that  the  Governance  Regulation 
played a role in influencing Member States to adopt or implement PaMs to meet 
national  energy  and  climate  contributions.  However,  several  (internal  and 
external) factors have negatively affected planning processes and the effective 
implementation of plans and reports. 

The  EU  has  an  overall  2050  climate  neutrality  target,  which  applies  collectively  to  the 
Union, but not to each Member State individually. In other words, the current EU legislative 
framework does not contain economy-wide national climate neutrality targets. Under the 
reporting framework in Annex I to Implementing Regulation 2022/2299142, each Member 
State  is  expected  to  report  on  their  climate  neutrality  target,  if  such  a  target  has  been 
introduced,  setting  out  the  target  years  when  this  will  be  achieved.  This  requirement  is 
therefore aligned to 2030 targets (for climate and energy) where there are Union targets 
and  Member  State  contributions  (the  only  exception  is  the  ESR  coverage  of  GHG 
emissions). 

Planning processes 

Prior  to  the  adoption  of  the  Governance  Regulation,  there  were  scattered  planning  and 
reporting obligations from the main pieces of EU legislation on energy, climate, and other 
Energy Union-related policy areas. Some of the more prominent obligations included: (1) 
EED  requiring  production  of  National  Energy  Efficiency  Action  Plans  (NEEAPs);  (2)  RED 
requiring production of National Renewable Energy Action Plans (NREAPs); and (3) MMR 
creating  a  system  for  monitoring  and  reporting  climate-related  information,  including 
reporting on (i) transfers under the EU ETS and the ESD 143 (Article 7); (ii) GHG emissions 
projections under the ETS and ESD (Article 14); and national adaptation actions (Article 
15)).  The  Governance  Regulation  provided  a  major  step  forward  by  streamlining  and 
integrating planning, reporting, monitoring, and data collection on energy and climate. 

138 Interview with third sector organisation (1). 
139  Replies  to  CfE:  NGOs  (4),  EEB,  Transport  and  Environment,  Environmental  Justice  Network  Ireland,  CAN 
Europe.  Environmental  organisations  (3):  WWF  European  Policy  Office,  Baltic  environmental  organisations, 
Estonian  Fund  for  Nature.  EU  citizen.  Public  authority  from  ES:  Ministry  for  the  Ecological  Transition  and  the 
Demographic Challenge.  
140 Reply to CfE: EEB. 
141 Reply to CfE: NGO: CAN Europe.  
142  Commission  Implementing  Regulation  (EU)  2022/2299  of  15  November  2022  laying  down  rules  for  the 
application of Regulation (EU) 2018/1999 of the European Parliament and of the Council as regards the structure, 
format, technical details and process for the integrated national energy and climate progress reports, https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R2299&qid=1707831881860 
143  Decision  No  406/2009/EC,  which  covered  non-ETS  sectors  including  CO2  emissions  reductions  from  road 
vehicles, renewables, landfill sites, the circular economy and fluorinated GHGs. 

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The  Governance  Regulation  requires  Member  States  to  establish  several  climate  policy-
making processes, which provide a baseline of ‘minimum governance standards’ at national 
level. These include dedicated planning tools, such as: the NECPs for actions over the next 
10  years  and  national  LTS  looking  30  years  ahead;  biennial  progress  monitoring  and 
reporting obligations; and channels for public and stakeholder participation through multi-
level  climate  and  energy  dialogues.  Despite  these  obligations,  research  shows  a  very 
diverse landscape of national energy and climate governance. Some Member States have 
implemented only minimum governance standards, while others exceed the requirements 
set forth by EU law with comprehensive national legal frameworks144. For instance, some 
Member  States  (e.g.  Finland,  France,  Germany,  Greece,  Luxembourg,  Portugal,  Spain, 
Sweden) have a dedicated and comprehensive climate framework law (including a long-
term  target  and  some  means  of  reaching  it),  while  others’  laws  are  missing  a  concrete 
long-term target (e.g. Bulgaria, Croatia, Malta)145.  

Evidence from the survey of national authorities indicates that the Governance Regulation 
helped to streamline the planning processes across the energy and climate domains (see 
Figure 12). More specifically, 12 of the 33 national authorities either agreed (seven)146 or 
strong agreed (five) 147 with the assertion that the Governance Regulation has helped  to 
streamline and simplify planning process at national level. Conversely, eight respondents 
disagreed  (four)148  or  strongly  disagreed  (four)149,  six  were  undecided150  and  seven  did 
not  reply151.  The  survey  of  national  authorities  did  not  explore  participants’  reasons  for 
agreeing or disagreeing with this statement.  

Figure 12. National  authorities’  views  on  whether  the  Governance  Regulation  helped  to 

streamline and simplify their planning processes (N=26) 

Source: ICF, based on survey of national authorities.  

144 Evans, N. Schöberlein, P. and Duwe, M. Raising the bar on national climate governance in the EU, Ecologic 
Institute, Berlin, forthcoming. 
145 Ibid.   
146 Survey of national authorities (7): DE, EE, ES (2), HU, LU, NL.  
147 Survey of national authorities (5): BE, BG, ES, HR, SK.  
148 Survey of national authorities (4): DK (2), FI, SE.   
149 Survey of national authorities (4): FI, LT, LV, MT.   
150 Survey of national authorities (6): AT, CY, CZ, FI, FR, SE.   
151 Survey of national authorities (7) DE (3), HR, PL (3).   

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Just over half (18 of 33) of the national authorities that responded to the survey agreed 
(12)152 or strongly agreed (six)153 that the Governance Regulation has helped to integrate 
different but related planning obligations (see Figure 13). Only two disagreed 154, and one 
strongly disagreed 155. Three respondents neither agreed nor disagreed156 and eight did not 
reply 157.  

Figure 13. National authorities’ views on whether the Governance Regulation has helped to 

integrate different but related planning obligations (N=24) 

Source: ICF, based on survey of national authorities.  

Seventeen  of  33  respondents  agreed  (10)158  or  strongly  agreed  (seven)159  that  the 
Governance  Regulation  has  helped  to  improve  the  quality  and  accuracy  of  the  planning 
processes.  Three  authorities  disagreed160,  two  strongly  disagreed161,  and  three  neither 
agreed nor disagreed162. Seven authorities did not reply (see Figure 14)163.  

152 Survey of national authorities (12): AT, CY, CZ, DE, EE, ES, FI, HR, LT, LU, SE, SK.   
153 Survey of national authorities (6): BE, BG, ES (2), MT, NL.   
154 Survey of national authorities (2): DK (2). 
155 Survey of national authorities (1): FI.  
156 Survey of national authorities (3): FI, HU, LV.  
157 Survey of national authorities (8): DE (3), HR, PL (3), SE.  
158 Survey of national authorities (10): CY, CZ, DE, EE, ES, FI, LT, LU, MT, NL.   
159 Survey of national authorities (7): BE, BG, ES (2), HR, HU, SK.  
160 Survey of national authorities (3): DK (2), SE.   
161 Survey of national authorities (2): FI. LV.   
162 Survey of national authorities (3): AT, FR, SE.   
163 Survey of national authorities (7): DE (3), HR, PL (3).    

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Figure 14. National authorities’ views on whether the Governance Regulation has helped to 
improve the quality and accuracy of their planning processes (N=26) 

Source: ICF, based on survey of national authorities.  

National  authorities  agreed  (12) 164  or  strongly  agreed  (six) 165  that  the  Governance 
Regulation has urged different  services to cooperate to comply with integrated planning 
obligations. Four authorities neither agreed nor disagreed166 and one strongly disagreed 167. 
Two respondents indicated a lack of knowledge168 and eight authorities did not reply (see 
Figure 15)169.  

164 Survey of national authorities (12): CY, CZ, DE, EE, FI, FR, HU, LT, LU, LV, NL, SE.   
165 Survey of national authorities (6) BE, BG, ES (2), MT, SK.   
166 Survey of national authorities (4): AT, DK, FI, HR.  
167 Survey of national authorities (1): FI. 
168 Survey of national authorities (2): DK, ES.  
169 Survey of national authorities (8): DE (3), HR, PL, SE.  

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Figure 15. National  authorities’  views  on  the  Governance  Regulation’s  influence  in 
stimulating  cooperation  among  different  services  to  comply  with  integrated 
planning obligations (N=25) 

Source: ICF, based on survey of national authorities.  

When  asked  to  give  examples  of  how  the  Governance  Regulation  has  contributed  to 
improving  and  integrating  planning  and  reporting  processes,  nine  national  authorities 
surveyed highlighted that it has increased cooperation between different institutions and 
ministries 170.  This  was  confirmed  by  feedback  gathered  through  other  consultation 
activities171. For instance, four national authorities explained during the scoping interviews 
that  the  Governance  Regulation  enhanced  cooperation  among  different  ministries  at 
national  level 172.  Nevertheless,  they  also  underlined  that  such  an  impact  necessitated 
additional  resources  to  ensure  coordination  among  different  actors  and  institutions.  A 
forthcoming study by Ecologic Institute reports that most Member States have relatively 
well-defined  responsibilities  for  climate  governance,  including  mechanisms  to  enhance 
coordination  between  relevant  authorities173.  However,  it  also  finds  that  despite  these 
existing  coordination  structures  and  assigned  competencies,  coordination  remains  a 
significant challenge due to competing priorities and a lack of communication (e.g. working 
in silos) in some Member States (e.g. Austria, Hungary, the Netherlands)174.  

Other  issues  that  impact  the  effectiveness  of  the  planning  processes  regulated  by  the 
Governance Regulation are presented below. 

  Article  15(6)  of  the  Governance  Regulation  provides  that  the  NECPs  must  be 
consistent  with  the  national  LTSs.  The  2022  Commission  guidelines  to  Member 
States  for  the  updated  NECPs  also  provide  that  NECPs  should  be  consistent  with 
national  LTSs.  However,  there  are  no  detailed  provisions  within  the  Governance 
Regulation  to  ensure  coherence  between  the  NECPs  and  LTSs,  with  the  latter 

170 Survey of national authorities (9): BG, CZ, EE, HR, LT, MT, NL, PL, SK.  
171 See case study on Romania  
172 Scoping interviews with national authorities (2): NL, CZ; Interviews with national authorities (2): DE, LT.  
173 Evans, N. Schöberlein, P. and Duwe, M. Raising the bar on national climate governance in the EU, Ecologic 
Institute, Berlin, forthcoming. 
174 Ibid. 

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attracting  less  attention  than  the  former 175.  In  this  context,  there  seems  to  be  a 
misalignment in the sequencing of NECPs and national LTS176: the first national LTSs 
had to be submitted after the NECPs, although they should have informed the latter. 
National LTSs are partly outdated and do not necessarily serve as the basis for NECP 
development.177  Unlike  the  NECPs,  there  is  no  strong  monitoring  or  mandatory 
update of the national LTSs after their adoption 178.  

  In  some  Member  States,  the  NECPs  are  not  particularly  relevant  for  national 
planning processes and are only developed to meet the EU obligation. Stakeholders 
indicated  that  in  some  cases,  the  NECPs  are  viewed  mainly  as  a  compilation  of 
existing  plans  and  policies  and  as  a  box-ticking  exercise179,  while  others  use  the 
Governance Regulation as a guiding tool in their planning processes 180. For instance, 
feedback gathered for the case studies on Germany and Denmark showed that the 
NECPs are not driving national energy and climate policies. Evidence also shows that 
the development of the national LTSs is somewhat isolated from day-to-day policy 
discussions at national level and is seen more as a response to an EU request than 
a concrete strategic planning tool guiding key policies at national level181.   

Effective implementation of plans and reports  

The  Governance  Regulation  requires  Member  States  to  report  every  two  years  on  the 
progress achieved towards the implementation of their integrated NECPs through NECPRs. 
By 15 March 2023, Member States were due to report for the first time on their progress 
towards  implementing  their  NECPs  for  the  period  2021-2030,  and  notably  towards  the 
objectives,  targets  and  contributions  set  out  therein,  across  the  five  dimensions  of  the 
Energy Union. Eight Member States submitted a full NECPR by the 15 March deadline, while 
10 more submitted their reports relatively close to the deadline. As of 1 March 2024, all 
Member States had submitted their NECPRs.   

The 2023 Commission assessment of progress towards the objectives of the Energy Union 
and Climate Action (based on NECPRs and other information/indicators) found that while 
substantial progress has been made towards the EU targets on GHG emissions, renewable 
energy,  energy  efficiency  and  interconnectivity,  substantial  ambition  and  implementing 

175  Replies  to  CfE:  (7):  NGOs  (4):  CAN  Europe,  Transport  and  Environment,  ZERO  –  Association  for  the 
Sustainability of the Earth System, WWF Greece.  Environmental organisations (2): WWF European Policy Office, 
Estonian  Fund  for  Nature.  Academic/Research  institute  (1):  Ecologic  Institute.  Interviews  with  third  sector 
stakeholders (4). 
176 Replies to CfE: NGO: CAN Europe. Academic/Research Institute: Ecologic Institute.; Velten et al., Charting a 
path to net zero: An assessment of national long-term strategies in the EU, Ecologic Institute, Berlin, 2022. 
177 Velten, E.K., Evans, N., Spasova, D., Duwe, M., de la Vega, R., Duin, L. and Branner, H., Charting a path to 
net zero: An assessment of national long-term strategies in the EU, Ecologic Institute, Berlin, 2022. 
178  Replies  to  CfE:  NGOs  (2):  CAN  Europe,  Transport  and  Environment.  Environmental  Organisation:  WWF 
European Policy Office. Academic/Research Institute: Ecologic Institute. Interviews with third sector stakeholders 
(3). During the stakeholder workshop on 11/01/2024, one stakeholder highlighted the need to include a closer 
assessment of the LTSs, similar to that for the NECPs.  
179 Replies to CfE: (4): Research institute: Ecologic Institute; Public authority: Danish Ministry of Climate, Energy 
and Utilities. Business association: EGEC Geothermal. Academic/Research institute: Wuppertal Institut für Klima, 
Umwelt, Energie; Interviews with third sector stakeholders (6); Scoping interview with NCAs (2): Netherlands, 
Denmark. Feedback gathered during the stakeholders’ event on 11 January 2024. UNIFY, Getting the Long-Term 
Planning Right: The role of National Long-Term Strategies in achieving climate neutrality in Europe, 2021.  
180 Replies to CfE: (4): Research institute: Ecologic Institute; Public authority: Danish Ministry of Climate, Energy 
and Utilities. Business association: EGEC Geothermal. Academic/Research institute: Wuppertal Institut für Klima, 
Umwelt, Energie; Interviews with third sector stakeholders (6); Scoping interview with NCAs (2): Netherlands, 
Denmark. Feedback gathered during the stakeholders’ event on 11 January 2024. UNIFY, Getting the Long-Term 
Planning Right: The role of National Long-Term Strategies in achieving climate neutrality in Europe, 2021.  
181 Haase, I. and Duwe, M.,  Long-term strategies: state of play, challenges, and possible support through the 
G20, Ecologic Institute, Berlin, 2023. 

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efforts are still needed to deliver on the increased 2030 Union’s objectives 182. On certain 
dimensions,  the  Commission  assessment  underlined  that  providing  a  collective  EU 
assessment was challenging, as reports varied across Member States, there were different 
interpretations,  and  information  was  sometimes  insufficient.  Table  12  presents  some 
examples from the Commission’s assessments.  

Table 12.  Commission assessment of progress towards the objectives of the Energy Union 

and Climate Action, 2023  

2023 Commission assessment of progress towards the objectives of the Energy Union and 
Climate Action 

  Decarbonisation 

  GHG  emission  and  removals:  All  Member  States  reported  progress  towards  national 
objectives,  targets,  and  contributions.  However,  reports  varied  across  Member  States  and 
information was largely insufficient to provide a collective EU assessment.  

  Climate  neutrality:  More  than  half  of  the  Member  States  defined  the  objective  to  achieve 

climate neutrality by 2050 or earlier, in line with their national LTSs.  

  National GHG targets: Most Member States have indicated quantitative national GHG targets 
up  to  2050,  but  not  for  all  required  years  (2030,  2040,  2050)  and  with  a  different  scope. 
Therefore,  assessing  progress  against  previously  indicated  national  targets,  such  as  those 
reported  in  their  LTSs  was  not  straightforward.  For  the  few  cases  where  comparison  was 
possible, Member States had generally increased their climate ambitions. The GHG emission 
projections supporting the NECPRs show that for the economy-wide GHG emissions reductions, 
existing and planned measures reduce emissions by 2030 by 45 % and 50 %, respectively, 
below  1990  levels.  This  is  an  improvement  compared  to  the  41 %  below  1990  levels  under 
existing and planned measures estimated in the 2020 EU-wide assessment of NECPs, but falls 
short  of  the  EU  55 %  reduction  target,  clearly  showing  that  additional 
implementation efforts are needed. 

  Progress towards ESR targets: Based on the GHG inventories (which also comprise LULUCF) 
and ETS emissions in stationary installations, EU-wide emissions in the ESR sectors in 2021 
remained 3.3 % below Member States’ aggregated emissions limits for 2021. Based on GHG 
projections,  EU-wide  ESR  emissions  are  estimated  to  reduce  by  32 %  in  2030  compared  to 
2005 levels. This would be underachieving against the EU-wide ESR target of 40 %.  

  Progress towards LULUCF targets.  Projections  with existing  measures  show  EU  total net 
removals of -239 MtCO2eq for 2030 and -260 MtCO2eq with additional measures, leaving a 
gap of between around 50-70 MtCO2e to meet the 2030 target. This means that the EU is not 
on track to meet the 2030 net removal target of -310 MtCO2eq. Very few Member States show 
a concrete pathway to reach their national LULUCF net removal targets, or sufficient actions to 
assist farmers, foresters and other stakeholders in building sustainable business models in line 
with these targets in their draft NECPs. This also includes limited reporting on synergies with 
the CAP and national CSPs and funding. 

  Climate  adaptation:  Article  4  of  the  Governance  Regulation  requires  Member  States  to 
include climate adaptation goals in the NECPs, as appropriate, to support the achievement of 
the  Energy  Union  objectives,  at  least  in  the  ‘decarbonisation’  dimension.  The  Regulation’s 
requirements  for  adaptation  goals  are  formulated  partly  in  a  conditional  way.  Outside  the 
decarbonisation dimension’s GHG emissions part, such goals were mandatory only if applicable. 
The relationship of these adaptation goals to those set out in the national adaptation policies 
(on which reporting was required under Article 19) has been a source of confusion. This has 

182 European Commission, Assessment of progress towards the objectives of the Energy Union and Climate Action, 
SWD(2023, 646 final. 

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2023 Commission assessment of progress towards the objectives of the Energy Union and 
Climate Action 

led to diverging interpretations among Member States of how adaptation is to be tackled in the 
NECPs, which makes it challenging to compare and assess progress horizontally.  

  Renewable energy: In 2021, the EU reached a share of 21.8 % of renewable energy in gross 
FEC, slightly below the target of the binding interim trajectory share of 22.2 % for 2022 based 
on the 2030 target of 32 % in RED II and would be more than 2 percentage points (pp) below 
this trajectory when considering the updated target of 42.5 % (the milestone would be slightly 
above  24 %).  The  new  2030  EU  target of  42.5 %  (and  the  aspirational target  of  45 %)  will 
require much faster growth in the coming years. Progress has been especially strong in the 
electricity sector, with an increase in the renewables share from 21.3 % in 2010 to 37.6 % in 
2021, progress in heating and cooling (from 17 % to 22.9 %), and transport (from 5.5 % to 
9.1 %).  While  final  numbers  for  2022  are  not  available  yet,  an  acceleration  of  renewables 
deployment  can  be  expected,  although  not  yet  at  the  level  required  for  the  updated  2030 
target. 

  Energy efficiency 

  Progress towards indicative trajectory and 2030 savings contribution:  In 2021, PEC 
in the EU at 1311 Mtoe remained lower than in 2019, but was around 6% higher than in 2020, 
most probably affected by the COVID-19 crisis recovery. This trend could indicate, if continued 
in  the  coming  years,  the  structural  improvements  that  took  place  in  the  two-year  period. 
However, PEC and FEC values are still far from the 2030 PEC and FEC targets.  

  Energy savings obligation: The average of new annual energy savings in 2018-2020 for the 
same  25  Member  States  was  10341  ktoe/year.  The  energy  savings  reported  for  2021  are 
therefore about the same as the trend in the years 2018-2020 (for these 25 Member States). 
However, the EED recast has revised the required equivalent rates of new annual savings, with 
a  progressive  increase.  Due  to  the  cumulative  nature  of  the  energy  savings  obligation,  the 
results achieved in the first years of a period are essential for the likelihood of achievement of 
the  target.  A  higher  rate  of  savings  than  needed  does  not  mean  that  a  Member  State  will 
achieve its target. However, a significantly lower rate of savings in the first years of a period 
can be very difficult to compensate in the remaining years of the period.  

  Progress towards the LTRS: The Commission analysis of the LTRSs submitted by Member 
States revealed that although the strategies complied with the requirements of the EPBD, not 
every LTRS is sufficiently ambitious in respect of 2050 decarbonisation goals. The differences 
in Member States’ approaches when setting national milestones made it difficult to assess the 
ambition  at  EU  level.  The  NECPR  includes  specific  reporting  tables  for  Member  States’ 
milestones and progress indicators of the LTRS of the national stock of residential and non-
residential buildings. Even if with some important differences in sub-indicators (e.g. residential 
vs non-residential buildings, entries in 2020 being more complete than in 2021), on average, 
completeness of the reported data was limited in most of the topics and indicators, except for 
the only mandatory field – contribution of buildings to the Union’s energy efficiency target. 

  Energy security 

  Overall, most Member States set national objectives and targets related to energy security 
in the 2019 NECPs. In the NECPRs, only seven Member States reported at least one specific 
quantifiable target or objective for the diversification of energy sources. However, almost all 
of these Member States registered some progress, which is a very positive development. These 
targets  were  most  often  related  to  the  increase  in  renewable  energy  share  and  biofuel 
production.  

  Progress  towards  reducing  energy  import  dependency  from  third  countries  is  mixed. 
Only six Member States have set quantifiable targets and objectives for the reduction of energy 
import  dependency  from  third  countries  (Bulgaria,  Croatia,  Estonia,  Greece,  Italy,  Poland). 
Among the countries that set dedicated targets, some reported no significant progress (e.g. 
Greece) or even registered a worsening of the situation (e.g. Croatia, Poland). Only Bulgaria, 

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Italy and Estonia have registered some progress. This appears insufficient within the context 
of the current geostrategic situation.  

  On  the  ability  to  cope  with  constrained  or  interrupted  supply  of  an  energy  source, 
Member States must now meet filling targets to ensure a minimum level of storage in the EU 
in the winter season (as per the adoption of the Gas Storage Regulation EU 2022/1032). As of 
September 2023, all Member States were on track to meet their targets, ensuring a filling level 
of 95 % in early October 2023.  

 

In  terms  of  preparedness  of  the  gas  sector,  progress  appears  positive,  with  most  countries 
achieving significant progress on the resilience of their gas and power systems. 

  Several  Member  States  reported  objectives  on  the  development  of  electricity  storage  and 
flexibility,  again  with  good  progress.  This  is  a  very  positive  development,  as  storage  and 
flexibility  will  be  critical  in  ensuring  the  stability  of  the  future  power  system  featuring  an 
increasing share of intermittent renewables.  

  Finally,  most  Member  States  that  set  targets  related  to  diversification  and  reducing 

dependencies did not report significant progress.  

 

Internal energy market 

  Electricity  interconnectivity:  In  2021,  20  Member  States  had  electricity  interconnectivity 
levels above the 2020 (10 %) and 2030 (15 %) EU targets. Overall, Member States have made 
good  efforts  to  increase  cross-border  capacity  and  the  completion  of  various  projects  of 
common  interest  (PCIs)  should  further  improve  the  interconnectivity  levels.  Some  Member 
States are reporting delays in the completion of the projects, notably due to permitting issues. 
Further efforts are required to meet the 2030 objectives, especially timely delivery of cross-
border projects. 

  Energy  system  flexibility:  While  the  timely  and  correct  transposition  of  the  provisions  on 
flexibility  in  Directive  (EU)  2019/944  (Electricity  Directive)  is  of  utmost  importance, 
development  of  flexibility  services  remains  slow.  Some  Member  States  reported  significant 
progress towards the integration of intraday and day-ahead market with full market coupling 
of the Member States at end-2022 or further integration of the balancing market. While these 
improvements are welcome, integration of balancing markets through EU platforms remains 
too scattered and effects on price signals and system flexibility are unclear. Not all Member 
States appear to have defined national objectives relating to energy system flexibility. Of those 
who have, the objectives vary in adaptability and measurability. Some Member States have 
already progressed with the integration of flexible energy sources in their electricity systems. 
  Non-discriminatory  participation  in  energy  markets  is  a  key  pillar  of  energy  market 
liberalisation.  Only  16  Member  States  reported,  however,  indicating  having  set  targets  and 
objectives  to  facilitate  the  non-discriminatory  participation  of  certain  market  actors.  Most 
reported  positive  progress  on  the  integration  of  renewables,  demand  response  and  energy 
storage in a non-discriminatory way through day-ahead and intraday market coupling. 

  Consumer participation in the energy system and benefits from self-generation and 
new  technologies,  including  smart  meters.  Many  Member  States  are  setting  ambitious 
goals  to  involve  consumers  in  the  energy  transition.  Progress  towards  national  objectives  is 
promising and efforts demonstrate a collective commitment to embracing innovative solutions 
and sustainable practices in the energy sector. Challenges remain, however, such as the need 
for accelerated smart meter rollout and the development of clear progress indicators in certain 
cases. The roll-out of smart meters has been relatively successful in 17 Member States, but 
six have made only limited progress and four reported no roll-out at all. 

  Electricity  system  adequacy.  Regulation  (EU)  2019/943  requires  Member  States  with  an 
adequacy  concern  to  develop  and  execute  an  implementation  plan  (market  reform  plan), 
setting out how they intend to address the root causes of their adequacy problem with market 
reforms. Member States implementing or intending to implement a capacity mechanism must 

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set  their  own  reliability  standard  at  national  level.  To  date,  very  few  Member  States  have 
calculated  the  reliability  standard  according  to  the  framework.  References  to  progress  on 
electricity system adequacy remain vague and do not allow overall conclusions to be drawn. 

  Research & Innovation (R&I) and competitiveness 

  The  European  SET  Plan  provides  a  platform  of  cooperation  among  Member  States  for  the 
coordination of their research and development (R&D) efforts183. Overall, 20 Member States 
reported measures implementing SET Plan objectives and policies at national level. There is a 
variety  of  national  approaches,  with  12  Member  States  providing  information  on 
implementation  progress  (e.g.  number  of  demonstration  projects  supported,  spending  on 
R&D), noting advances towards at least one of their targets. For three Member States, it is too 
early to assess progress, as support measures implementing the targets are not yet in place 
or were implemented only recently. Five Member States provided no indicators.  

  Overall,  19  Member  States  provided  some  information  on  quantifiable  national  objectives 
relating to public spending on R&I, and five reported against a target. Of the 13 Member States 
that reported data for both 2020 and 2021, 12 recorded an increase in R&I investment (Austria, 
Czechia, Finland, France, Germany, Lithuania, Malta, Netherlands, Portugal, Romania, Spain, 
Sweden),  and  only  one  a  slight  decrease  (Greece).  Five  Member  States  included  some 
information on private expenditure on R&I.  

  Eighteen Member States reported on non-quantifiable national objectives related to public 
spending on R&I. There are significant differences in Member States' approaches to reporting. 
Of the 23 Member States that submitted NECPRs, 15 provided information on progress towards 
national objectives on the deployment of technologies for decarbonising energy- and carbon-
intensive  industrial  sectors.  Eleven  also  reported  progress  towards  at  least  one  of  their 
objectives.  

  Thirteen  Member  States  reported  on  the  progress  towards  national  objectives  related  to 

competitiveness, eight of which noted advances in this field. 

  Energy poverty. A wide range of approaches and outcomes to addressing energy poverty can 
be observed among Member States, based either on quantitative targets or more qualitative 
assessments.  While  some  countries  have  seen  positive  progress,  others  face  challenges  in 
providing clear progress assessments. In winter 2022, Member States put in place a significant 
number of emergency measures that contributed to containing the impact of the energy crisis 
on the most vulnerable households.  

PaMs are all instruments that contribute to meeting the objectives of the integrated NECPs 
and/or to implementing commitments under the UNFCCC184.  

The 2023 Commission assessment revealed that the total number of single PaMs increased 
from 2 052 in 2021 to 3 039 in 2023185. However, there were still significant differences 
among Member States in the number of reported PaMs, with some reporting their PaMs at 

183 The SET Plan is currently being revised to meet the objectives of the European Green Deal, REPowerEU, ERA 
and the Green Deal Industrial Plan. 
184 May include those that do not have the limitation and reduction of GHG emissions or change in the energy 
system as a primary objective; Article 2 of the Governance Regulation.  
185 Figures provided in the 2023 Commission assessment did not include PL, due to delayed submission. The EEA 
PaMs  database  shows  that  the  total  number  of  PaMs  is  3 205  (includes  EEA  member  countries),  
https://pam.apps.eea.europa.eu/?source=%7B%22track_total_hits%22%3Atrue%2C%22query%22%3A%7B
%22match_all%22%3A%7B%7D%7D%2C%22display_type%22%3A%22tabular%22%2C%22sort%22%3A%5
B%7B%22Country%22%3A%7B%22order%22%3A%22asc%22%7D%7D%2C%7B%22ID_of_policy_or_meas
ure%22%3A%7B%22order%22%3A%22asc%22%7D%7D%5D%2C%22highlight%22%3A%7B%22fields%22
%3A%7B%22*%22%3A%7B%7D%7D%7D%7D  

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a  highly  disaggregated  level  and  others  reporting  at  a  more  aggregated  level.  Overall, 
there  was  a  large  increase  in  newly  implemented  PaMs  (i.e.  put  in  place  following  the 
adoption  of  the  NECPs).  This  increase  may  suggest  that  many  Member  States  have 
implemented (or will have to implement) new PaMs to meet their 2030 climate and energy 
objectives. The lack of sufficient information on ex-ante and ex-post data on the impacts 
of  PaMs  makes  it  challenging  to  track  Member  State  progress  in  implementing  their 
NECPs186. The 2023 Climate Action Progress Report highlights the need for Member States 
to step up their action to assess the effects of implemented policies more systematically, 
both ex ante and ex post187. 

In  the  survey  of  national  authorities,  24  out  of  33  respondents  indicated  that  the 
Governance Regulation played a role in influencing Member States to adopt or implement 
PaMs to meet national energy and climate contributions, to some extent (11)188, to a large 
extent (eight)189, or to a very large (five) extent190. Only two national authorities reported 
that the Regulation’s impact was small191, while another indicated that the Regulation had 
no influence at all in this respect 192. Two respondents indicated their lack of knowledge on 
the matter (see Figure 16)193. 

Figure 16. National  authorities’  views  on  Governance  Regulation’s  influence  on  Member 

States adopting or implementing PaMs 

Source: ICF, based on survey of national authorities.  

The 2023 Commission assessment reveals that, as of October 2023, 286 (33 %) PaMs are 
currently  planned,  219  (25 %)  are  adopted  and  359  (41 %)  are  implemented,  showing 

European 

Commission, 

186 EEA, Overview of reported integrated national climate and energy policies and measures in Europe in 2023, 
2023.  
187 
https://climate.ec.europa.eu/system/files/2023-11/com_2023_653_glossy_en_0.pdf  
188 Survey of national authorities (11): BE, BG, DE, ES, FI (2), FR, MT, NL, PL.  
189 Survey of national authorities (8): CY, CZ, EE, ES (2), HR, LU, LV.  
190 Survey of national authorities (5): FI, HR, HU, LT, SK.   
191 Survey of national authorities (1): DK (Danish Energy Agency). 
192 Survey of national authorities (1): DK (Danish Ministry of Climate, Energy and Utilities). 
193 Survey of national authorities (2): DE (2). 

Progress 

Climate 

Report, 

Action 

2923, 

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that  additional  action  is  being  taken194.  Figure  17  shows  the  number  of  single  PaMs 
reported by Member States in different reporting years.  

Figure 17. Number of single PaMs reported by Member States in different reporting years 

Source:  EEA,  Overview  of  reported  integrated  national  climate  and  energy  policies  and 
measures in Europe in 2023, 2023. 

Across the EU, the number of PaMs per dimension is very varied (see Figure 18). The most 
common dimension is decarbonisation (2 452 single PaMs), at 81 %, which is 1 500 single 
PaMs  more  than  the  second  most  common  dimension,  energy  efficiency.  The  research, 

194 Most new PaMs target energy supply (28 %), energy consumption (27 %) and transport (25 %). Relatively 
more new PaMs target agriculture (14 % new, compared to 11 % overall) and LULUCF (9 % new, compared to 
7 %  overall).  Most  new  PaMs  are  economic  (51 %),  regulatory  (33 %)  and/or  planning  (17 %)  instruments. 
Relatively  more  new  PaMs  are  economic  instruments  (51 %  new,  compared  to  43 %  overall)  and  planning 
instruments (17 % new, compared to 13 % overall), with a slight decrease in the share of regulatory and fiscal 
measures. Most  new  PaMs  are  national  (90 %), with  a  small  number being  regional,  local,  or  covering  two or 
more countries (European Commission, Assessment of progress towards the objectives of the Energy Union and 
Climate Action, 2023).  

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innovation  and  competitiveness  dimension  and  the  energy  security  dimension  most 
frequently see countries reporting no single PaM. 

Figure 18. Number of PaMs per dimension reported by Member State  

Source: EEA, Overview  of  reported integrated national climate  and energy policies and measures in 
Europe in 2023, 2023. 

In 2023, 18 countries reported indicators for at least one PaM, compared to 12 countries 
in  2021.  In  2023,  17  countries  reported  at  least  one  policy  indicator  and  15  countries 
reported at least one indicator (see Figure 19).  

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Figure 19. Number of PaMs and policy indicators reported by Member States  

Source:  EEA,  Overview  of  reported  integrated  national  climate  and  energy  policies  and 
measures in Europe in 2023, 2023. 

Notes: Number of PaMs with policy indicator: number of PaMs with a least a description of 
a policy indicator; number of PaMs with quantified policy indicator: number of PaMs with a 
least  a  description  of  a  policy  indicator  and  one  value  for  at  least  one  year;  Number  of 
policy indicators: number of policy indicators per PaM with a description, indicators can be 
the  same  for  different  PaMs;  Number  of  quantified  policy  indicators:  number  of  policy 
indicators  per  PaM  with  a  description  and  one  value  for  at  least  one  year;  number  of 
quantified data: number of values reported for each policy indicator and PaM, values can 
be reported for more than one year. 

Some Member States (Austria, Italy, Romania) did not report information on the financing 
of PaMs, while those that did often reported incomplete or inconsistent data (see EQ4)195.  

In  the  2023  NECPRs,  over  three-quarters  of  Member  States  reported  the  objective  to 
achieve  climate  neutrality  by  2050  or  earlier196.  As  of  2023,  21  Member  States  have  a 

195 European Commission, Assessment of progress towards the objectives of the Energy Union and Climate Action, 
2023.  
196 European Commission, Climate Action Progress Report, 2023.  

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target for reaching climate neutrality197, 14198 of which are contained in a dedicated climate 
law or are legally binding199.  

Feedback from other consultation activities revealed that the enforcement mechanism of 
the Governance Regulation is a key factor hindering the effective implementation of plans 
and reports (see EQ3).  

Finally, across all Member States, there is a lack of national processes for monitoring the 
implementation of LTSs and progress towards long-term goals200.  

5.1.1.3  EQ3 - How effective has the Governance Regulation been in responding to 

any ambition or implementation deficits (enforcement)?  

The  Governance  Regulation  has  been  only  partially  effective  in  responding  to 
implementation  deficits.  Stakeholders  underlined  that  the 
ambition  or 
Regulation’s  enforcement  mechanism  is  hampered  by  the  fact  that  it  is  largely 
based  on  recommendations,  which  are  not  legally  binding,  and  some  countries 
did not systematically address the Commission’s recommendations.  

The  Governance  Regulation  (Chapter  5)  created  a  monitoring  system  to  track  the 
implementation of the 2030 framework and the associated targets at EU and Member State 
level.  Where  the  draft  NECPs  or  their  draft  updates  show  insufficient  ambition,  the 
Commission ‘shall’ (for the renewable energy target) and ‘may’ (for the other targets of 
the Energy Union) recommend that the relevant Member State(s) increase its ambition to 
ensure  a  sufficient  overall  level  of  ambition  across  the  Union  (Article  31(1)  Governance 
Regulation)201. 

Where the Commission concludes, based on its aggregate assessment of Member States’ 
integrated NECPRs, that there is a risk of not meeting the objectives of the Energy Union, 
it may issue recommendation to all Member States (Article 32(2) Governance Regulation). 
The Commission’s recommendations to Member States thus constitute the key response 
during  the  planning  and  implementation  phases.  Although  not  binding,  the  Governance 
Regulation requires Member States to take due account of those recommendations. 

When surveyed, 14 out of 33 national authorities agreed (13) 202 or strongly agreed (one) 203 
that the Governance Regulation’s enforcement mechanism is sufficient and appropriate to 
address insufficient national contributions to or implementation of EU energy and climate 
objectives. No respondent disagreed, although nine neither agreed nor disagreed204, three 
lacked knowledge 205, and seven did not answer 206. Conversely, in the survey of third sector 
stakeholders, 14  out  of 20  respondents disagreed (12) or strongly disagreed (two) with 
the  statement  that  the  Governance  Regulation’s  enforcement  mechanisms  are  sufficient 
and fit for purpose to address insufficient national contribution to or the implementation of 

197 AT, CY, DE, DK, EE, EL, ES, FI, FR, HU, IE, IT, LT, LU, LV, NL, PT, RO, SE, SI, SK. Evans, N. Schöberlein, P. 
and Duwe, M. Raising the bar on national climate governance in the EU, Ecologic Institute, Berlin, forthcoming.  
198 DE, DK, EE, EL, ES, FI, FR, HU, IE, LT, LU, PT, SE, SI. Evans, N. Schöberlein, P. and Duwe, M. Raising the bar 
on national climate governance in the EU, Ecologic Institute, Berlin, forthcoming. 
199 Evans, N. Schöberlein, P. and Duwe, M. Raising the bar on national climate governance in the EU, Ecologic 
Institute, Berlin, forthcoming.  
200 Velten, E.K., Evans, N., Spasova, D., Duwe, M., de la Vega, R., Duin, L. and Branner, H., Charting a path to 
net zero: An assessment of national long-term strategies in the EU, Ecologic Institute, Berlin, 2022. 
201  As  per  the  ESR  and  LULUCF  Regulation,  when  the  Commission  finds  that  a  Member  State  is  not  making 
sufficient progress towards meeting its obligations, that Member State must submit a corrective action plan that 
includes a detailed explanation of the matter.  
202 BE, BG, CY, CZ, DK, EE, ES (3), FR, LU, NL, SK.  
203 MT.   
204 DE, DK, FI, HR (2), HU, LT, LV, PL.   
205 DE, FI (2).  
206 AT, DE (2), PL, SE (2).  

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EU  energy  and  climate  objectives  (see  Figure  20).  Only  two  third  sector  stakeholders 
agreed and four respondents did not reply.  

Figure 20. National  authorities  and  third  sector  stakeholders’  views  on  the  Governance 

Regulation’s enforcement mechanisms  

Source: ICF, based on surveys of national authorities and third sector stakeholders. 

Fifteen out of 33 national authorities agreed (14)207 or strongly agreed (one)208 that the 
Regulation’s enforcement mechanisms were effectively deployed when there was a need 
to address insufficient national contributions to or implementation of EU energy and climate 
targets. Two national authorities disagreed 209, four neither agreed nor disagreed210, five 
did  not  know 211,  and  seven  did  not  reply 212.  Results  from  the  survey  with  third  sector 
stakeholders were mixed. Of the 20 respondents, five agreed with the statement that the 
enforcement mechanisms were effectively deployed, and others either disagreed (four) or 
strongly disagreed (one). Four respondents neither agreed nor disagreed and four did not 
reply (see Figure 21).  

207 BE, BG, CY, CZ, EE, ES (3), FR, HR, HU, LU, NL, SK.  
208 MT.  
209 DK, HR.   
210 DE, DK, LV, PL.   
211 DE, FI (3), LT.  
212 AT, DE (2), PL (2), SE (2).  

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Figure 21. National  authorities  and  third  sector  stakeholders’  views  on  the  effective 

deployment of the Governance Regulation’s enforcement mechanisms  

Source: ICF, based on surveys of national authorities and third sector stakeholders.  

When asked why they think the enforcement mechanism is ineffective, six respondents to 
the  survey  of  third  sector  stakeholders  highlighted  that  the  enforcement  mechanism  is 
largely ensured through recommendations, which are not legally binding.  

Evidence  from  the  CfE  and  targeted  interviews  similarly  shows  that  some  stakeholders 
doubt  the  effectiveness  of  the  Governance  Regulation’s  enforcement  mechanisms.  More 
specifically, 16 respondents to the CfE and 16 interviewees (mainly from the third sector 
and  EU  institutions)  reported  that  the  Governance  Regulation  has  not  been  effective  in 
ensuring  a  strong  enforcement  framework213.  The  main  weakness  of  the  enforcement 
mechanism,  according  to  stakeholders,  lies  in  the  fact  it  is  based  on  recommendations, 
which  are  not  legally  binding.  Stakeholders  also  explained  that  infringement  procedures 
may  only  be  initiated  in  response  to  Member  States’  non-compliance  with  procedural 
obligations (e.g. failure to submit the NECP on time), but not following instances of failure 
to achieve targets. They also underlined that the Commission’s recommendations following 
the  draft  NECPs  were  not  all  addressed  in  the  final  NECPs.  This  is  confirmed  by  the 
Commission’s assessments of the final NECPs. An ICF review of the annexes included in 
the  Commission’s  country-specific  assessments  (looking  at  the  extent  to  which  the 
Commission’s recommendations were addressed by Member States in their final NECPs) 
revealed  that  the  majority  (66 %,  378)  of  recommendations  were  either  partially 

213 Replies to CfE: NGOs (10): EEB; CAN Europe; Transport and Environment; Renewables Grid Initiative (RGI); 
Natural  Resources  Defense  Council;  Youth  and  Environment;  Germanwatch  e  V;  WWF  Greece;  Environmental 
Justice Network Ireland (EJNI); Association for the Sustainability of the Earth System. Business association (1): 
European Renewable Energies Federation. Environmental organisations (3): Estonian Fund for Nature, Estonian 
Green  Movement,  Green  Liberty;  Baltic  environmental  organizations;  WWF  European  Policy  Office. 
Academics/Research institutes (2): Ecologic Institute; Brussels School of Governance. Interviews with third sector 
stakeholders  (12);  Interviews  with  EU  Institutions  (2);  Scoping  interviews  with  EU  Institutions  (2);  Feedback 
gathered at the stakeholders’ event on 11 January 2024.  

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addressed (53 %, 304), or not addressed at all (13 %, 74) by Member States (see Figure 
22). 

Figure 22. Status  of  recommendations  as  per  the  annexes  included  in  the  Commission’s 

country-level assessment of final NECPs (N=571) 

Source: ICF, based on mapping of the annexes included in the country-level assessments 
of the final NECPs produced by the European Commission 214 

Industry  and  national  authorities  interviewed  did  not  have  specific  opinions  on  the 
effectiveness of the enforcement mechanism. However, two national authorities underlined 
challenges or factors related to actual implementation of the targets. One highlighted that 
deficits  in  the  ambition  of  targets  do  not  depend  on  NCAs  but  on  political  decision-
making215.  For  example,  evidence  shows  that  contentious  discourse  and  politicisation  of 
climate issues have hindered progress on several fronts, including adopting binding legal 
architecture at national level 216.  

5.1.1.4  EQ4 - What difference has the Governance Regulation made in terms of 

stimulating spending and investment? 

The  limited  evidence  on  the  extent  to  which  the  Governance  Regulation  has 
stimulated  spending  and  investment  that  targets  the  achievement  of  the  EU’s 
energy and climate objectives is mixed. The Commission’s assessments revealed 
that  NECPs  lack  detail  on  investment  needs  and  funding  sources.  Stakeholders 
were  unable  to  link  targeted  spending  and  investment  to  the  Governance 
Regulation, although some acknowledged the positive impact of the Governance 
Regulation in creating a more predictable environment for investors.  

The  Governance  Regulation  sought  to  enhance  regulatory  and  investor  certainty  and 
facilitate opportunities for economic development, investment stimulation, job creation and 
social cohesion (Article 1 (1)(d)). Accordingly, Article 7 of the Regulation requires Member 
States to provide a general overview of the investment needed to achieve the objectives, 
targets and contributions set out in their national plans, as well as a general assessment 

Commission 

assessments, 

214 
https://commission.europa.eu/energy-climate-change-
environment/implementation-eu-countries/energy-and-climate-governance-and-reporting/national-energy-and-
climate-plans_en  
215 Interview with national authority (BE). 
216 Evans, N. Schöberlein, P. and Duwe, M. Raising the bar on national climate governance in the EU, Ecologic 
Institute, Berlin, forthcoming. 

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of the sources of that investment. In accordance with Article 17(2)(a) and Article 21(b)(7), 
Member States must report information on their progress towards financing the PaMs, or 
groups of PaMs, and must review actual investment against initial investment assumptions.  

Evidence  from  the  desk  research  shows  that  the  draft  NECPs  did  not  provide  sufficient 
detail on investment needs and financing sources217. That lack of structurally reported data 
on investment needs and financing sources reduces predictability for investors and hinders 
informed policy analysis218.   

The 2020 EU-wide assessment of the final NECPs found that, compared to the draft NECPs, 
Member States presented an improved overview of the expected investments needed to 
achieve  the  various  objectives,  targets  and  contributions219.  Nevertheless,  some  of  the 
NECPs  lacked  sufficient  detail  to  enable  total  investment  needs  for  energy  and  climate 
objectives to be summed or compared 220. A 2022 study led by CAN Europe found that this 
was  particularly  true  of  investment  needs  in  circular  economy  and  biodiversity221.  To 
address the lack of detail on investment needs, the 2022 Commission guidance to Member 
States for the update of the NECPs urged Member States to provide a detailed financing 
plan  addressing  the  investment  needs  for  each  of  the  five  dimensions  of  the  Energy 
Union222.  

A 2022 assessment of the national LTSs by the Ecologic Institute found that almost all LTSs 
contain  information  on  financing  aspects223.  Four  Member  States  provide  guidance  on 
finance qualitatively, while 12 also provide data on investment needs until 2050224. These 
investment needs are mainly the ‘additional investment needs’, i.e. those associated with 
reaching the 2050 climate target and are in addition to what would have been invested in 
the reference case. 

ZERO 

2050, 

Planning 

217  NET 
the  Draft  NECPs, 
https://www.ecologic.eu/sites/default/files/publication/2019/2149-necp-assessment-ecologic-institute-
climact_20190516.pdf;  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the 
European  Economic  and Social  Committee  and  the Committee  of  the  Regions,  United  in  delivering  the  Energy 
Union and Climate Action - Setting the foundations for a successful clean energy transition, COM/2019/285 final, 
https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1565713062913&uri=CELEX:52019DC0285  

for  Net 

Assessing 

2019, 

Zero: 

to 

the 

final, 

2030 

reach 

actions 

planning, 

COM(2020) 

218 The EU Climate Funding Tracker was developed by Agora energiewende that aims to provide an overview of 
funding sources, showing their allocation across Member States and sectors, and an assessment of the EU funding 
contribution  in  closing  the  national  investment  gaps,  https://www.agora-energiewende.org/data-tools/eu-
climate-funding-tracker  
219 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee  and  the Committee  of  the  Regions,  An  EU-wide  assessment  of  National  Energy  and Climate 
Plans:  Driving  forward  the  green  transition  and  promoting  economic  recovery  through  integrated  energy  and 
climate 
https://eur-lex.europa.eu/legal-
564 
content/EN/TXT/PDF/?uri=CELEX:52020DC0564  
220 Ibid., European Court of Auditors, EU climate and energy targets. 2020 targets achieved, but little indication 
that 
2023, 
targets  will 
https://www.eca.europa.eu/ECAPublications/SR-2023-18/SR-2023-18_EN.pdf  
221 CAN Europe, Taking Stock & Planning Ahead. NECPs as a tool to achieve climate safety and energy security, 
2022, p. 8, https://caneurope.org/taking-stock-planning-ahead-national-energy-and-climate-plans-as-a-tool-to-
achieve-climate-safety-and-energy-security/  
222  The  guidelines  also  provide  that  ‘innovative  approaches  such  as  insurance  policies  and  fiscal  measures 
addressing  the  climate  protection  gap,  may  also  be  considered,  as  well  as  investments  aimed  at  preserving 
biodiversity that would contribute to climate adaptation’ (Commission Notice on the Guidance to Member States 
for  the  update  of  the  2021-2030  national  energy  and  climate  plans,  2022/C  495/02,  https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52022XC1229(02).   
223 Velten, E.K., Evans, N., Spasova, D., Duwe, M., de la Vega, R., Duin, L. and Branner, H., Charting a path to 
net zero: An assessment of national long-term strategies in the EU, Ecologic Institute, Berlin, 2022. 
224 CZ, EL, ES, FI, FR, HU, LV, MT, PT, SI, SK. Excluding countries that do not provide any figure and those without 
LTSs (BG, CY, IE, PL, RO). Velten, E.K., Evans, N., Spasova, D., Duwe, M., de la Vega, R., Duin, L. and Branner, 
H.,  Charting  a  path  to  net  zero: An  assessment of  national  long-term strategies  in  the EU,  Ecologic  Institute, 
Berlin, 2022. 

sufficient, 

Special 

report, 

be 

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Energy Union and Climate Action 

On progress towards financing, the 2023 Commission assessment of progress towards the 
objectives of the Energy Union and Climate Action found that225:  

  Some Member States (Austria,  Italy, Romania) did not report on the  financing of 
PaMs. Those that did provide information often reported incomplete or inconsistent 
data; 

  Overall, the most important data gaps related to actual investments and appropriate 
accounting of the source of the funds employed (national public, European, private 
funds).  Several  Member  States  failed  to  report  any  support  from  the  EU  budget, 
which  appears  inconsistent  with  other  information  available  at  EU  level  (e.g. 
allocations  from  Cohesion  Policy  funds).  This  lack  of  proper  reporting  on  funding 
sources fails to accurately identify funding needs and gaps, which is central to sound 
strategic  planning  and  implementation.  It  also  makes  it  impossible  to  assess  the 
effectiveness of public support and its impact on public finances; 

  The  high  level  of  incompleteness  prevents  an  actual  division  between  national, 

European, and private funds allocated by Member States. 

It  was  not  possible  to  compare  Member  States’  submissions,  as  the  timelines  for 
investment  assumptions  differ.  Implementation  periods  of  single  PaMs  vary  because 
investment  assumptions  –  especially  those  related  to  financial  allocations  to  specific 
national  financing  schemes/programmes  or  specific  investments  –  are  determined  by 
national  procedures  setting  budgetary  allocations  for  the  specific  measure.  In  the  next 
reporting  cycle,  it  will  be  important  to  reflect  on  ways  to  increase  the  consistency  and 
comparability of information on financing. 

Survey  respondents  had  mixed  views  on  the  Governance  Regulation’s  contribution  to 
improving predictability and certainty for public and private investors. Although there were 
no substantial differences between respondent types (see Figure 23; Figure 24; and Figure 
25), public authorities tended to feel more positively about the impact of the Governance 
Regulation compared to representatives from industry and the third sector.  

Across all surveys, 27 respondents reported that the Governance Regulation contributed 
to  increased  predictability  and  certainty  for  public  and  private  investors  to  some  extent 
(17), a large (eight)226, or a very large extent (two)227. Conversely, 14 reported that the 
Governance Regulation contributed to increased predictability and certainty for investors 
to only a small extent228, and others reported no contribution at all (seven)229. In addition, 
22 respondents indicated a lack of knowledge (11)230 or chose not to answer (11)231 (see 
Figure 23). 

225  Report  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions,  State  of  the  Energy  Union  Report  COM(2023),  650  final, 
https://eur-lex.europa.eu/resource.html?uri=cellar:b27b8b93-725d-11ee-9220-
01aa75ed71a1.0001.02/DOC_1&format=PDF 
226  Survey  of  national  authorities  (4):  BE,  CY,  ES,  SK;  Survey  of  industry stakeholders  (2);  Survey with  third 
sector stakeholders (2). 
227 Survey of national authorities: ES (2).  
228 Survey of national authorities (4): AT, DK, FI, FR; Survey of industry stakeholders (3); Survey of third sector 
stakeholders (7). 
229 Survey of national authorities (1): LV; Survey of industry stakeholders (4); Survey of third sector stakeholders 
(2). 
230 Survey of national authorities (7): DE (2), DK, FI (2), HR, NL; Survey of industry stakeholders (2); Survey of 
third sector stakeholders (2). 
231 Survey of national authorities (8): DE (2), EE, LU, PL (2), SE (2); Survey of industry stakeholders (1); Survey 
of third sector stakeholders (2) 

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Figure 23. Survey  respondents’  views  on  the  Governance  Regulation’s  contribution  to 

higher predictability and certainty for public and private investors 

Source: ICF, based on surveys of national authorities, industry stakeholders, third sector 
stakeholders.  

Twenty-six respondents (across all surveys) indicated that national plans and reports 
have  created  a  clearer,  more  predictable  environment  and  have  stimulated  public 
investment to some extent (14)232, a large extent (10)233, or a very large extent (two) 234. 
Conversely,  18  reported  that  national  plans  and  reports  have  created  a  clearer,  more 
predictable  environment  and  have  stimulated  public  investment  to  a  small  extent  only 
(11)235, or made no contribution at all (seven)236. Fifteen respondents indicated a lack of 
knowledge237 and 11 did not reply238 (see Figure 24).  

232 Survey of national authorities (7): BG, CZ, ES, FR, HU, LT, PL; Survey of industry stakeholders (5); Survey of 
third sector stakeholders (2). 
233 Survey of national authorities (5): BE, CY, HR, MT, SK; Survey of third sector stakeholders (3); Survey of 
industry stakeholders (2).  
234 Survey of national authorities (2): ES (2).  
235 Survey of national authorities (3): AT, DK, LV; Survey of industry stakeholders (3); Survey of third sector 
stakeholders (5). 
236 Survey of national authorities (1): FI; Survey of industry stakeholders (4); Survey of third sector stakeholders 
(2).  
237  Survey  of  national  authorities  (7):  DE  (2),  DK,  FI  (2),  HR,  NL;  Survey  of  third  industry  stakeholders  (6); 
Survey of industry stakeholders (2). 
238 Survey of national authorities (8): DE (2), EE, LU, PL (2), SE; Survey of third sector stakeholders (2); Survey 
of industry stakeholders (1). 

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Energy Union and Climate Action 

Figure 24. Stakeholders’ views on whether national plans and reports created a clearer and 

more predictable environment and stimulated public investment   

Source: ICF, based on surveys of national authorities, third sector stakeholders, industry 
stakeholders.  

Twenty-three  respondents  (across  all  surveys)  indicated  that  national  plans  and  reports 
have created a clearer, more predictable environment and stimulated private investment 
to some extent (13)239, a large extent (eight) 240, or a very large extent (two) 241. A slightly 
smaller number (19) reported that national plans and reports have created a clearer, more 
predictable environment and stimulated private investment to only a small extent (12) 242 
or  made  no  contribution  at  all  (seven)243.  Nineteen  respondents  indicated  a  lack  of 
knowledge244 and nine chose not to answer (see Figure 25).  

239 Survey of national authorities (8): BG, CY, ES, FR, HR, LT, MT, PL; Survey of third sector stakeholders (2); 
Survey of industry stakeholders (3). 
240  Survey  of  national  authorities  (2):  BE,  SK;  Survey  of  third  sector  stakeholders  (3);  Survey  of  industry 
stakeholders (3). 
241 Survey of national authorities (2): ES (2).  
242  Survey of  national  authorities  (3): DK, FI,  HU;  Survey of third  sector  stakeholders  (6);  Survey of  industry 
stakeholders (3). 
243 Survey of national authorities (1): LV; Survey of third sector stakeholders (2); Survey of industry stakeholders 
(4). 
244 Survey of national authorities (9): AT, CZ, DE (2), DK, FI (2), HR, NL; Survey of third sector stakeholders (6); 
Survey of industry stakeholders (4). 

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Figure 25. Stakeholders’ views on whether national plans and reports created a clearer and 
more predictable environment and stimulated private investment   

Source: ICF, based on surveys of national authorities, third sector stakeholders, industry 
stakeholders.  

Table  13  presents  some  examples  of  key  investments  stimulated  by  national  plans  and 
reports under the Governance Regulation. The information was collated from stakeholders’ 
replies to the surveys.  

Table 13.  Investments mentioned by stakeholders in their survey responses   

Survey 
stakeholder 
type 

National 
authorities 

Examples of investments mentioned by survey respondents  

  Belgium: 

  H2 backbone. 

  Cyprus: 

  National  planning  for  RRP  and  structural  funds  was  based  on  the 
NECP. Support schemes and other projects under national funds were 
based on the NECP. 

  Spain: 

 

Investments in renewable energy private projects, stimulated by the 
implementation of the Recovery, Transformation and Resilience Plan 
in Spain.  

  Lithuania: 

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Survey 
stakeholder 
type 

Examples of investments mentioned by survey respondents  

  Offshore wind farms, requiring key private investments.  

  Hungary: 

 

Investments of the power sector (network, storage, electrolysers).  

  Malta: 

  Support schemes for solar PVs in households and businesses (grants 
and  feed-in-premiums),  installation  of  battery  energy  storage 
systems  in  combination  with  solar  PVs,  installation  of  solar  water 
heaters and heat pump water heaters in residential. 

 

Investment in renewable energy technologies.  

  The  Greek  government’s  NECP  provided  a  clear  roadmap  for  the 
country’s  transition  to  a  low-carbon  economy,  which  has  helped  to 
attract public investment in renewable energy, energy efficiency and 
other  clean  technologies  (reply  from  a  research  institution  from 
Greece). 

 

In Belgium, ECOLISE has been able to continue research on energy 
communities (in EU-funded projects, such as COMETS) (reply from a 
non-profit association).  

Industry 
stakeholders 

Third 
stakeholders 

sector 

Source:  replies  to  surveys  of  national  authorities,  industry  stakeholders,  third  sector 
stakeholders.  

On  public  and  private  spending  on  R&I  relating  to  clean  energy  technologies,  the  2023 
Commission  assessment  of  progress  towards  the  objectives  of  the  Energy  Union  and 
Climate Action revealed that245: 

  Nineteen  Member  States  provided  some  information  on  quantifiable  national 
objectives relating to public spending on R&I, and five reported against a target. Of 
the 13 Member States that reported data for both 2020 and 2021, 12 recorded an 
increase in R&I investment (Austria, Czechia, Germany, Finland, France, Lithuania, 
Malta, the Netherlands, Portugal, Romania, Spain, Sweden), and only one a slight 
decrease (Greece). Five Member States also provided some information on private 
expenditure  on  R&I.  As  several  Member  States  reported  only  partially,  and  there 
were seemingly encoding errors, it was difficult to provide an informed assessment 
at  EU  level,  beyond  stressing  the  need  to  improve  capacity  and  consistency  in 
monitoring and reporting of R&I spending in clean energy technologies; 

  Eighteen Member States reported on non-quantifiable national objectives related to 
public  spending  on  R&I.  There  were  significant  differences  in  Member  States’ 
approaches to reporting. Member States reported a wide range of targets related to 
the development of clean technologies. In several cases, the support measures or 
programs were technology-specific. 

245 European Commission, Assessment of progress towards the objectives of the Energy Union and Climate Action, 
SWD(2023, 646 final. 

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  In the targeted survey of national authorities, participants were reminded that one 
of the objectives of the Governance Regulation is to encourage public and private 
investment and economic development towards delivering climate and energy goals. 
Participants  were  then  asked  to  consider  whether  public  and,  where  available, 
private  spending  has  been  dedicated  to  R&I  relating  to  clean  energy  and 
decarbonisation  technologies,  as  well  as  lowering  costs  and  improving  the 
performance  of  such  technologies.  Of  the  33  national  authorities  that  replied,  15 
indicated that public and/or private spending has been dedicated to R&I relating to 
clean energy and decarbonisation technologies, at least to some extent 246. Of these 
15, five reported this is the case to a very large extent (four)247, or to a large extent 
(one)248. Three authorities indicated that this objective has been achieved only to a 
small extent249, and one reported ‘not at all’250. Six authorities indicated a lack of 
knowledge251 and eight chose not to reply (see Figure 26)252.  

Figure 26. National  authorities’  views  on  allocation  of  public/private  spending  for  R&I 

relating to clean energy and decarbonisation technologies (N=25) 

Source: ICF, based on survey of national authorities.  

Six  industry  stakeholders  noted  an  increase  in  public  spending  for  R&I  associated  with 
cleaner  energy  and  decarbonisation  technologies  to  some  extent.  However,  contrasting 
views  were  expressed,  with  three  respondents  stating  no  increase  at  all,  two  indicating 
only  a  small  increase,  and  four  expressing  uncertainty  (see  Figure  27).  It  appears  that 
national authorities and industry stakeholders concur.  

246 Survey of national authorities (10): AT, BG, CY, CZ, ES, FR, HR, HU, MT, PL.  
247 Survey of national authorities (4): ES (2), NL, SK.  
248 Survey of national authorities (1): BE. 
249 Survey of national authorities (3): DK, FI, LT.  
250 Survey of national authorities (1): LV.  
251 Survey of national authorities (6): DE (2), DK, FI (2), HR.  
252 Survey of national authorities (8): DE (2), EE, LU, PL (2), SE (2). 

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Energy Union and Climate Action 

Figure 27. Industry  stakeholders’  views  on  increased  public  spending  for  R&I  relating  to 

cleaner energy and decarbonisation technologies (N=17) 

Source: ICF, based on survey of industry stakeholders.  

During the interviews, 11 stakeholders indicated that the NECPs might have contributed to 
creating  a  more  predictable  environment  for  investors253.  They  noted  that  the  NECPs 
provided a useful overview of national policies and intended actions on the different Energy 
Union dimensions, which is important background for investors. However, 14 stakeholders 
expressed uncertainty about the extent to which the Governance Regulation has stimulated 
spending  and  investment,  with  several  noting  that  it  is  difficult  to  monitor  or  attribute 
increases to the Regulation254. Stakeholders noted some factors that may have hindered 
the potential of the Governance Regulation in creating a more predictable environment for 
investors:  

  Twenty-one  stakeholders  highlighted  information  gaps  within  the  NECPs  on 
investment  needs  for  the  green  transition  and  their  sources 255.  It  is  not  clear 
whether these data deficiencies originate directly from the Governance Regulation 
or  issues  at  national  level,  although  three  third  sector  stakeholders  pointed  to 
Member State capacity to effectively map this type of information 256;  

253 Interviews with industry stakeholders (1); Interviews with national authorities (3); Interviews with third sector 
stakeholders  (3);  Interviews  with  EU  institutions  (1);  Scoping  interviews  with  EU  institutions  (2);  Scoping 
interview with national authority (1). During the stakeholder event on 11 January 2024, one national authority 
from Germany underlined that NECPs constitute a helpful tool that enhance certainty for investors. 
254  Interviews  with  industry  stakeholders  (1);  Interviews  with  national  authorities  (1);  Interviews  with  EU 
institutions (3); Interviews with third sector stakeholders (5); Scoping interviews with EU institutions (2), NCAs 
(2). 
255  Interviews  with  EU  institutions  (2);  Interviews  with  third  sector  stakeholders  (8);  Interviews  with  industry 
stakeholders  (2);  Scoping  interviews  with  EU  institutions  (3),  Scoping  interview  with  national  authorities  (2); 
Replies  to  CfE:  NGOs (2):  Transport  and  environment;  Renewable  Grid  Initiative;  Environmental  Organisation 
(1): WWF European Policy Office; Academic/Research Institute (1): Ecologic Institute.  
256 Interviews with third sector stakeholders (3). 

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  Seven  stakeholders  reported  that  investors  might  need  information  with  a  more 
extended timeframe and a long-term perspective257. They deemed the timeframe of 
the NECPs (2021-2030) too short, with some noting that the LTSs are more relevant 
in this sense (taking a perspective of at least 30 years). This potentially hinders the 
development of a comprehensive forward-looking perspective, which is crucial for 
investors;  

  Four  stakeholders  mentioned  that  NECPs  provide  information  aimed  at  an  expert 
audience,  that  investors  might  not  find  the  NECPs  particularly  user-friendly,  and 
that third sector stakeholders are more interested in the NECPs processes258. One 
stakeholder  underlined  a  similar  concern  about  the  NECPRs,  while  other  industry 
stakeholders stressed the importance of fully understanding what investors need in 
terms  of  the  type  and  granularity  of  data  from  NECPs  (e.g.  at  regional  and  local 
level)259.  

A  review  of  the  annexes  included  in  the  Commission’s  country-specific  assessments  (on 
the extent to which the Commission’s recommendations were addressed by Member States 
in  their  final  NECPs)  reveals  that  while  14  (out  of  33)  recommendations  related  to 
investments  and  funding  sources  were  addressed  largely  (11)  or  fully  (three),  16 
recommendations were only partially addressed, and three were not addressed at all (see 
Figure 28).  

Figure 28. Status of recommendations on investments and funding sources as per annexes 

included in the Commission’s country-level assessment of final NECPs (N=33) 

Source: ICF, based on mapping of the annexes included in the Commission’s country-level 
assessments of the final NECPs.  

Article  33  of  the  Governance  Regulation  established,  as  of  January  2021,  a  Union 
Renewable  Energy  Financing  Mechanism  (REFM)  to  tender  support  for  new  renewable 
energy projects, with the aim of covering a gap in the indicative Union trajectory.   

257 Interviews with industry stakeholders (1); Interviews with third sector stakeholders (2); Survey response from 
industry stakeholders (1); Survey response from third sector stakeholders (1); Survey response from national 
authorities (2).  
258 Interview with national authority (1); Interview with third sector stakeholder (1); Feedback gathered during 
the stakeholders’ event on 11 January 2024 (2). 
259 Feedback gathered during the stakeholders’ event on 11 January 2024 (3). 

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Renewable Energy Financing Mechanisms (REFM) 

The  European  Commission  established  the  REFM  to  better  support  renewable  energy 
projects and encourage greater uptake of RES across the EU. The Mechanism allows two 
or  more  countries  to  jointly  support  new  renewable  projects  by  providing  the  funding 
and  the  territory.  The  REFM  links  countries  that  voluntarily  pay  into  the  Mechanism 
(contributing countries) with countries that agree to have new projects built on their soil 
(hosting  countries).  The  Commission  facilitates  the  common  agreement  of  the 
contributing and host countries on the conditions and criteria under which the support 
will be granted.  

Following  a  binding  commitment  by  Finland  and  Luxembourg,  the  first  cross-border 
tender for renewables opened on 18 April 2023 and closed on 27 September 2023. It 
provides investment support to solar PV installations located in Finland with a minimum 
capacity of 5 MW and a maximum of 100 MW. The maximum total capacity of the call is 
400 MW. For the next 15 years, Luxembourg and Finland will share the statistical benefits 
of the electricity produced by the supported projects. The Commission is organising the 
next call for proposals in 2024. 

Sources:  European  Commission,  EU 
https://energy.ec.europa.eu/topics/renewable-energy/financing/eu-renewable-energy-
financing-mechanism_en  

renewable  energy 

financing  mechanism, 

Only three stakeholders mentioned the REFM during the interviews or in the CfE and none 
mentioned it during the surveys. Two stakeholders questioned whether the REFM is used 
to its full extent260. For instance, one stakeholder reported that the first tender under the 
REFM was not particularly successful, with only Finland (host) and Luxemburg (contributor) 
willing to cooperate.  

One public authority (Denmark), replying to the CfE, underlined that the current setup of 
the REFM is not suitable, especially for offshore wind projects. It noted that the Mechanism 
is  only  partially  adequate  for  procurement  purposes  (e.g.  timing,  creating  the  right 
incentives for Member State participation when the fund beneficiary is a private actor, and 
the Commission’s role) and financing projects not producing renewable energy until after 
2030,  where  there  are  currently  no  targets  for  renewable  energy  production  or 
consumption261.   

5.1.1.5  EQ5  -  How  successful  has  the  Regulation  been  in  ensuring  regional 

cooperation? 

The Governance Regulation has stimulated regional cooperation to some extent. 
Although several Member States engaged in regional cooperation through various 
forums  and  initiatives  on  different  dimensions  of  the  Energy  Union,  evidence 
shows that the potential of regional cooperation has yet to be fully exploited.  

Article 12(1) of the Governance Regulation requires Member States to take account of all 
existing  and  potential  forms  of  regional  cooperation  to  effectively  meet  the  objectives, 
targets and contributions set out in their NECPs. To promote such regional cooperation, in 
2022 the European Commission: 

260 Reply to CfE: (1) NGO: CAN Europe; Interview with third sector stakeholder (1). 
261 Reply to CfEL Public authority DK (Danish Ministry of Climate, Energy and Utilities). 

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  Adopted  a  guidance  notice  to  Member  States  on  the  update  of  the  NECPs,  which 
includes  guidance  to  strengthen  regional  cooperation  for  a  better  coordinated 
response and promotion of solidarity262;  

  Published  guidance  on  cost-benefit  sharing  in  cross-border  renewable  energy 
cooperation projects263 to support Member States willing to engage in cross-border 
cooperation projects pertaining to renewable energy;   

  Launched the EU Energy Platform to coordinate the work to diversify EU gas supplies 
away from Russian sources. The platform also created five regional groups (South-
East  Europe,  Central  Eastern  Europe,  North-West  Europe,  South-West  Europe, 
Baltics)  to  identify  needs,  opportunities  for  common  use  of  infrastructure,  and 
potential  new  suppliers.  These  regional  groups  meet  regularly  and  discuss  the 
potential for joint purchasing in each region.  

Both the 2019 EU-wide assessment of the draft NECPs and the 2020 EU-wide assessment 
of the final NECPs indicated the need to enhance regional cooperation efforts 264. The 2020 
EU-wide assessment found that while Member States properly understood and described 
the  need  for  regional  cooperation,  with  some  making  use  of  existing  regional  forums  in 
drawing up their NECPs, the full potential of regional cooperation has yet to be realised. 
The  2020  EU-wide  assessment  found  that  very  few  Member  States  described  specific 
measures  to  optimise  access  and  use  of  regional  facilities,  or  to  better  plan  renewable 
energy  deployment  and  energy  efficiency  measures  in  cooperation  with  other  Member 
States. It also indicated that Member States should make better practical use of regional 
cooperation, for example by using existing forums265 to address common issues affecting 
energy transition priorities, enhancing energy transition regionally.  

The 2023 Commission assessment of progress towards the objectives of the Energy Union 
and  Climate  Action  revealed  that  most  of  the  Member  States  reported  progress  in 
implementing regional cooperation, with most reporting some advances in at least one of 
their regional cooperation initiatives or projects266. There was insufficient information on 
progress in some cases, with very few not reporting at all. Reported regional cooperation 
projects  or  initiatives  span  the  five  dimensions  of  the  Energy  Union,  and  most  Member 
States reported projects related to more than one dimension. The majority focus on energy 
security,  internal  energy  market  and  decarbonisation,  with  fewer  projects  or  initiatives 
related to energy efficiency and research, innovation, and competitiveness. Some Member 
States reported cooperation only on one dimension, while others reported cooperation on 
all five dimensions (see Box 4).  

final, 

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C(2022) 

262 Commission Notice on the Guidance to Member States for the update of the 2021-2030 national energy and 
climate 
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52022XC1229(02)    
263  Commission  Notice  on  the  Guidance  on  cost-benefit  sharing  in  cross-border  renewable  energy  cooperation 
projects, 
https://energy.ec.europa.eu/system/files/2022-
9284 
12/C_2022_9284_F1_OTHER_AUTONOMOUS_ACT_EN_V2_P1_2356829.PDF  
264 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions, United in delivering the Energy Union and Climate Action - 
Setting  the  foundations  for  a  successful  clean  energy  transition,  COM(2019)  285  final,  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52019DC0285; Communication from the Commission to the 
European  Parliament,  the  Council,  the  European  Economic  and  Social  Committee  and  the  Committee  of  the 
Regions, An EU-wide assessment of National Energy and Climate Plans: Driving forward the green transition and 
promoting economic recovery through integrated energy and climate planning, COM(2020) 564 final, https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020DC0564    
265 Some positive examples identified included cooperation in the following groups: the Pentalateral, the Central 
and Southeastern Europe energy connectivity (CESEC), the Northern Seas initiative, and the Baltic countries (for 
example Estonia and Latvia are planning a joint auction for offshore wind). 
266 European Commission, Assessment of progress towards the objectives of the Energy Union and Climate Action, 
SWD(2023, 646 final. 

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Box 4. 

 Regional cooperation initiatives 

  High-level groups: providing strategic and policy guidance, monitoring progress 
of PCIs in priority regions. These include cooperation within the North Seas Energy 
Cooperation (see below), Interconnections for South-West Europe, the Baltic Energy 
Market  Interconnection  Plan,  and  the  Central  and  South  Eastern  Europe  Energy 
Connectivity.  

  The Pentalateral Energy Forum: a regional energy cooperation between Austria, 
Belgium, France, Germany, Luxembourg, the  Netherlands  and Switzerland, which 
was created in 2005. This forum contributes to objectives related to energy security, 
an integrated internal  energy market,  and decarbonisation (e.g. study on system 
flexibility  in  the  Penta  region  (including  synergies  from  regional  cross-border 
exchange of flexibility); implementing the risk preparedness regulation). 

  The  North  Seas  Energy  Cooperation,  which  facilitates  the  development  of 
offshore grid development and the large renewable energy potential in the region. 
Agreeing to reach at least 260 GW of offshore wind energy by 2050, for example. 

  The  EU  Energy  Platform,  within  which  five  regional  groups  were  set  up.  The 
Platform was  established in April 2022 to support the EU’s  security  of supply and 
access to affordable energy, including international outreach, demand aggregation, 
and efficient use of EU gas infrastructures. The regional groups agree action plans 
on  gas  demand,  including  potential  gas  demand  reduction,  infrastructure 
opportunities and supply options. On 1 June 2022, the Regional Energy Platform for 
South-East  Europe  agreed  an  action  plan  to  diversify  supply  and  bolster  energy 
security due to the disruption of gas supplies from Russia.  

  Strategies  (e.g.  EU  Strategy  for  the  Adriatic  Ionian  Region,  Mediterranean  CCS 
Strategies  Plan,  the  EU  Strategy  for  the  Baltic  Sea  Region,  the  Strategy  for  the 
Danube Region, joint regional risk assessment related to the security of natural gas 
supply – Ukrainian group and Belarusian group) and projects on market integration 
implemented  by  ENTSO-E  (IGCC,  MARI  and  PICASSO  projects,  CORE  CCR  and 
South-Eastern  Europe  Regional  Security  Coordinator),  Interreg  programmes,  CEF 
(e.g.  the  Baltic  Synchronisation  project),  Trans-European  Networks  for  Energy 
(TEN-E) initiatives, as well as the SET roadmap and the TARES technical assistance 
project. 

  Bilateral cooperation initiatives with other Member States, as well as bilateral 
gas  solidarity  agreements  or  multi-country  Memoranda  of  Understanding  (MoU), 
including  with  third  countries  (e.g.  Croatia  with  Bosnia  and  Herzegovina, 
Montenegro and Albania, or Greece with Israel, Egypt, Jordan, Saudi Arabia, United 
Arab Emirates, United States of America (US), and Italy with Tunisia, Switzerland 
and Montenegro). 

  Multilateral cooperation in the frame of the Transatlantic Partnership for Energy 
and Climate Cooperation. Several references have been made to the Union for the 
Mediterranean (Gas platform, Regional Electricity Market  Platform and Renewable 
Energy and Energy Efficiency Platform), the Organisation of the Black Sea Economic 
Cooperation (BSEC) and the Eastern Mediterranean Gas Forum (EMGF), enhancing 
regional cooperation among EU Member States and non-EU countries. 

Source:  European  Commission,  Assessment  of  progress  towards  the  objectives  of  the 
Energy Union and  Climate Action, SWD(2023,  646 final; European Commission website, 
Energy: high-level groups. 

Of  the  33  national  authorities  that  participated  in  the  survey,  14  (Belgium,  Bulgaria, 
Croatia,  Cyprus,  Denmark,  Finland  (three),  France,  Germany  (two),  Latvia,  the 
Netherlands, Poland) reported that their respective Member States have taken advantage 

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of, or increased, cooperation with other Member States, at least to some extent (11) 267, to 
a large extent (three)268, or to a very large extent (one)269 (see Figure 29). Eight reported 
that regional cooperation occurred to a small extent only270. One authority indicated a lack 
of knowledge271 and nine did not reply272. 

Figure 29. National  authorities’  views  on  the  extent  to  which  their  Member  States  took 

advantage of, or have increased, their cooperation with other Member States 

Source: ICF, based on survey of national authorities. 

A review of the annexes included in the Commission’s country-specific assessments reveals 
that 29 (of 51) recommendations related to regional cooperation were either fully (17) or 
largely  (12)  addressed  in  Member  States’  final  NECPs.  Eighteen  recommendations  were 
partially addressed and four were not addressed (see Figure 30).  

267 Survey of national authorities (11): BG, CY, DE (2), DK, FI (3), FR, HR, PL.  
268 Survey with national authorities (3): BE, LV, NL.   
269 Survey with national authorities (1): LT. 
270 Survey of national authorities (8): AT, CZ, DK, ES (3), HU, SK.  
271 Survey with national authorities (1): HR.  
272 Survey with national authorities (9): DE (2), EE, LU, MT, PL (2), SE (2). 

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Figure 30. Status of recommendations on regional cooperation as per annexes included in 

the Commission’s country-level assessment of final NECPs (N=51) 

Source: ICF, based on mapping of the annexes included in the Commission’s country-level 
assessments of the final NECPs.  

When interviewed, few stakeholders expressed an opinion on the Governance Regulation’s 
effectiveness in ensuring regional cooperation. However, four indicated that the Regulation 
had  a  positive  impact  in  ensuring  and  increasing  regional  cooperation  among  Member 
States273. 

Seven  national  authorities  underlined  that  even  before  the  adoption  of  the  Governance 
Regulation,  their  countries  were  engaged  in  a  form  of  regional  cooperation  with  other 
Member States274. Findings from the case  studies indicate regional cooperation between 
Member  States,  particularly  through  initiatives  such  as  the  Central  and  South-Eastern 
Europe  Connection  Initiative,  Pentalateral  Energy  Forum,  and  the  North  Seas  Energy 
Cooperation 275.  

Stakeholders emphasised some factors that hindered regional cooperation, such as short 
timelines  to  consult  NECPs  from  other  Member  States276  and  limited  comparability  or 
accessibility of data from other Member States (reports are lengthy and not always user-
friendly)277. All agreed that there is scope to enhance regional cooperation278, as does the 
evidence from the case studies on France, Germany and Poland279. 

273 Interview with national authority (1); Interviews with third sector stakeholders (2); Scoping interview with EU 
institution.   
274 Interviews with national authorities (3); Scoping interview with national authority (1); Case study on France: 
interview with national authority; Case study on Germany: interview with national authority; Case study on Malta: 
interview with national authority. 
275 Case studies on BE, DE, DK, FR, MT, PL, RO.  
276 Interview with national authority (1). 
277 Interview with national authority (1). 
278  Interviews  with  national  authorities  (4);  Interviews  with  third  sector  stakeholders  (2);  Interview  with  EU 
institution (1); Scoping interview with national authority; Scoping interview with EU institutions.  
279 Case study on DE, FR, PL.   

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5.1.1.6  EQ6.  How successful has the Regulation been in ensuring adequate multi-

level and multi-stakeholder dialogue and consultation?  

The  available evidence shows that  although the introduction  of  Articles  10  and 
11 of the Governance Regulation was perceived as a significant step forward, the 
Regulation has not been particularly successful in ensuring adequate multi-level 
and multi-stakeholder dialogue and consultation.  

Article 10 of the Governance Regulation requires Member States to ensure that the public 
is given early and effective opportunities to participate in the preparation of the draft NECPs 
and  LTSs.  It  also  specifies  that  each  Member  State  must  set  reasonable  timeframes 
allowing sufficient time for the public to be informed, participate, and express their views.  

Member States and the EU are Parties to the Aarhus Convention 280, which regulates access 
to  information,  public  participation  in  decision-making,  and  access  to  justice  in 
environmental matters. Article 7 of the Aarhus Convention provides for public participation 
on  plans,  programmes  and  policies  relating  to  the  environment,  mandating  that  ‘public 
participation  procedures  shall  include  reasonable  timeframes  for  the  different  phases, 
allowing  sufficient  time  for  informing  the  public’  and  ‘for  the  public  to  prepare  and 
participate effectively during the environmental decision-making’. Article 6 of the Aarhus 
Convention requires that public bodies in charge of such plans ‘ensure that in the decision 
due  account  is  taken  of  the  outcome  of  the  public  participation’.  Article  10  of  the 
Governance Regulation, read together with Recitals 28 and 29, is intended to support the 
Aarhus Convention requirements on public participation in national plans. This was clarified 
in the European Commission’s guidance to Member States for the update of the 2021-2030 
NECPs281.  

However, according to a recent report issued by the Brussels School of Governance282, the 
Governance  Regulation  does  not  fully  meet  the  environmental  democracy  standards 
established  by  the  Aarhus  Convention,  as  it  does  not  set  specific  qualitative  reporting 
obligations  or  mandatory  minimum  standards  with  which  Member  States  must  comply 
when  involving  the  public.  Article  17(7)  of  the  Governance  Regulation  requires  Member 
States to make their integrated NECPRs available to the public. NECPRs are submitted via 
two electronic platforms: Reportnet3 and ReportENER.  The Reportnet3 website is available 
to  the  public,  although  reporting  countries  can  restrict  some  information  from  public 
view283.  Meanwhile,  the  European  Commission  has  published  all  of  the  NECPRs  on 
ReportENER284. 

Annex  I,  Section  A,  Chapter  1.3  of  the  Governance  Regulation,  setting  the  general 
framework for integrated NECPs, asks for a narrative description of the ‘consultations of 
stakeholders, including the social partners, and engagement of civil society and the general 
public’.  However,  Article  10  fails  to  provide  clear  instructions,  reporting  obligations  or 
minimum standards. According to a report recently issued by the EEB285, lack of clarity on 
reporting on Article 10 (and on the confusion between Article 10 and Article 11) is evident, 

plans, 

2022/C 

280  United  Nations  Economic  Commission  for  Europe  (UNECE)  Convention  on  Access  to  Information,  Public 
Participation  in  Decision-making,  and  Access  to  Justice  in  Environmental  Matters  (Aarhus  Convention), 
https://unece.org/DAM/env/pp/documents/cep43e.pdf  
281 Commission Notice on the Guidance to Member States for the update of the 2021-2030 national energy and 
climate 
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52022XC1229(02)    
282 The EU’s climate and energy framework in light of the Aarhus Convention - assessing environmental democracy 
rights  in  the  Governance  Regulation,  https://www.greendealnet.eu/sites/default/files/2023-12/20231026-
Aarhus Convention and Governance Regulation_0.pdf  
283 Reportnet3, https://reportnet.europa.eu/public/dataflows  
284  CIRCABC,  EU  energy  and  climate  reporting,  https://circabc.europa.eu/ui/group/da8e36ea-9d6e-47fd-bc85-
a485cf354922/library/a15083a8-8613-402c-8ea7-6c1608cafdb6?p=2&n=10&sort=modified_DESC  
285  EEB,  NECP  Reporting 
content/uploads/2023/09/NECPs-reporting-report-Dec-23.pdf    

the  public,  2023,  https://eeb.org/wp-

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as  some  Member  States  used  Annex  XXIII  of  the  Implementing  Regulation  for  the 
NECPRs286  to  describe  their  public  consultations  as  per  Article  10  of  the  Governance 
Regulation (that specific annex should have been used for reporting on Article 11).  

According to a recent publication by the Ecologic Institute287, seven Member States (as of 
end-August 2023) had  successfully  established public  consultation processes or citizens’ 
juries  for  the  draft  updated  NECPs.  By  contrast,  according  to  the  draft  updated  NECPs 
themselves, most have successfully established consultation processes. However, almost 
none provide a comprehensive description of the process, the number of respondents, nor 
how they intend to integrate the comments into the final updated NECPs. This is stressed 
in  the  Commission’s  EU-wide  assessment  of  the  draft  NECP  updates,  as  well  as  in  the 
Commission’s recommendations to each Member State288. It was also confirmed by some 
of the stakeholders interviewed, who stated that:  

  In some Member States, consultations were not timely or were open only for a short 

period; 

  In  some  Member  States,  there  was  no  text  (draft  NECP)  available  when  the 

consultation was open;  

  The opportunity to provide feedback was sometimes limited in choice or length.  

Some interviewees commented on specific Member States:  

  In  Estonia,  public  accessibility  of  the  data  has  to  be  enhanced  (printable, 

forwardable and transferrable) and has to be improved;   

  In Italy, the consultation process was not adequate, meaningful or timely. A draft 
of the document was not shared with the public and no information was published 
on the official ministerial website; 

  In  Belgium,  there  was  a  lack  of  return  to  the  public  following  the  consultation 

process organised for the drafting of the first NECP in 2018-2019.  

Some  Member  States  (Denmark,  Lithuania,  Malta,  Spain,  Sweden)  indicated  that  they 
intend  to  use  the  time  between  the  submission  of  the  draft  updated  NECP  and  the 
submission  of  the  final  updated  NECP  to  carry  out  a  comprehensive  public  consultation 
process,  the  results  of  which  will  be  used,  together  with  the  European  Commission’s 
assessment, to improve the final version of the text.  

Article  11  of  the  Governance  Regulation  provides  that  Member  States  must  establish  a 
multi-level  climate  and  energy  dialogue  pursuant  to  national  rules,  in  which  local 
authorities, civil society organisations, business community, investors and other relevant 

States’ 

Member 

Assessing 

286  Commission  Implementing  Regulation  (EU)  2022/2299  of  15  November  2022  laying  down  rules  for  the 
application of Regulation (EU) 2018/1999 of the European Parliament and of the Council as regards the structure, 
format, technical details and process for the integrated national energy and climate progress reports, https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R2299&qid=1707831881860 
287 Faber, R., Kocher, D. and Duwe, M., Progress on the implementation of national Multilevel Climate and Energy 
Dialogues: 
2023, 
https://www.ecologic.eu/sites/default/files/publication/2023/33007-Multilevel-Climate-Energy-Dialogue-
Reporting-Preliminary-Assessment.pdf  
288 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions, 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,  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2023%3A796%3AFIN&pk_campaign=preparatory&pk_source=EURLEX&pk_medi
um=TW&pk_keyword=EUGreenDeal&pk_content=Communication&pk_cid=EURLEX_todaysOJ;  The  EU-wide 
assessment  mentioned  that  ‘the  quality  of  the  consultation  processes  varies,  and  many  did  not  cover  all  the 
above-mentioned obligations. In particular, the plans contain few details on the communication channels used to 
reach the public and, on the methods, used to involve a wide range of interest groups, including social partners 
and ordinary members of the public. Many plans lack reasonable timeframes to enable the public to express their 
views.  Most  draft  plans  do  not  include  the  summary  of  the  public’s  views  and  how  they  were  considered. 
Furthermore, details on the information provided to the public, and how the consultations contributed to the final 
content of the draft plans were not very comprehensive.’ 

reporting, 

own 

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stakeholders  and  the  general  public  are  able  to  actively  engage  and  discuss  the 
achievement  of  the  Union’s  climate-neutrality  objective  set  out  in  Article  2(1)  of  the 
European Climate Law, as well as the different scenarios envisaged for energy and climate 
policies (including long term), and review progress, unless it already has a structure which 
serves  the  same  purpose.  The  NECPs  may  be  discussed  within  the  framework  of  such 
dialogue.  

Evidence  for  compliance  with  Article  11  is  more  difficult  to  compile.  According  to  the 
European  Commission’s  assessment  of  the  NECPRs  in  2023289,  most  Member  States 
reported activities related to setting up or enhancing pre-existing permanent structures  to 
discuss national energy and climate policies (including NECPs and LTSs) with sub-national 
authorities  and  other  relevant  stakeholders.  It  appears,  however,  that  without  clear 
guidance on the size and type of stakeholders that need to be involved, and without clear 
guiding principles on how these structures need to be operationalised (e.g. structure of the 
dialogue, sharing responsibilities between participants – including organisation in charge, 
frequency of meetings), Member States had the flexibility to interpret Article 11 in different 
ways.    The  EEB  report290  highlights  that  coherence  and  comparability  between  Member 
States is almost non-existent. It also notes that the handful of countries that have carried 
out commendable dialogues have reported on them unsatisfactorily. 

According  to  a  recent  study  by  CAN  Europe 291,  most  Member  States  did  not  provide 
sufficient  evidence  of  existing  multi-level  governance  platforms.  The  exceptions  were 
Austria,  Croatia,  Cyprus,  Czechia,  Denmark,  Finland,  France,  Luxembourg  and  Portugal, 
with different levels of maturity and a wide margin for improvement. 

The  LIFE  NECPlatform  project292  has  supported  six  Member  States  (Bulgaria,  Croatia, 
France, Italy, Portugal, Romania) to set up multi-level governance dialogues, with mixed 
results.  In  June  2023,  the  project  drafted  some  conclusions  on  impediments  to  the 
process293: ‘In generic terms it can be said that national governments are accustomed to 
working with a top-down approach, and generally tend to work against European deadlines, 
rather than perceive the need of having long-term plans and strategies as a structured and 
continuous process. In some cases, then, the NECP is seen as a bureaucratic tool rather 
than  a  political  priority.  Moreover,  different  ministries  tend  to  think  in  silos,  so  that 
priorities are competing instead of building on one another. Furthermore, the non-binding 
nature of the NECP trajectories and the long-term horizon of the reduction targets leads 
national governments to dedicate little focus on the implementation of these targets and 
the necessary measures. The main challenge for any national planning exercise is to put 
measures into practice. However, this should be done consistently, in a concerted manner 
(including other stakeholders and sub-national authorities) and not according to political 
convenience’. 

  One respondent to the CfE mentioned that the framework for public participation in 
the  NECPs  is  not  sufficiently  clear  and  precise  and  that  there  has  not  been  a 
consistent  well-designed  public  participation  process  in  all  Member  States 294. 
Several  respondents  also  highlighted  shortcomings  with  respect  to  the  Aarhus 

-  The  missing  voice  of 

289 European Commission, Assessment of progress towards the objectives of the Energy Union and Climate Action, 
SWD(2023, 646 final. 
290  EEB,  NECP  Reporting 
content/uploads/2023/09/NECPs-reporting-report-Dec-23.pdf    
291 CAN Europe, Together for 1.5, Time to step up national climate action - An assessment of the draft National 
Energy and Climate Plans updates, 2023, https://caneurope.org/content/uploads/2023/10/NECPs_Assessment-
Report_October2023.pdf  
292 LIFE NECPlatform, https://energy-cities.eu/project/life-necplatform/  
293  LIFE  NECPlatform  policy  brief,  https://energy-cities.eu/wp-content/uploads/2023/06/NECPlatform_First-
Policy-Brief_Formatted_Final.pdf  
294 Reply to CfE: Environmental Justice Network Ireland.  

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obligations295, with one arguing that this undermines both the Commission’s ability 
to hold Member States accountable for their failures and the public’s right to access 
information, participation, and justice on climate (in)action 296. Respondents noted 
that  the  NECPs  submitted  in  2019  and  2023  showed  weak  compliance  with  the 
Governance  Regulation  rules  on  public  participation,  respect  for  deadlines,  and 
transparency and availability of information underpinning the plans. One respondent 
argued  that  while  a  lot  of  these  rights  are  already  granted  in  theory,  in  practice, 
better implementation and enforcement may increase the Regulation’s added value 
in this area 297. 

The  interviews  carried  out  for  this  study  confirmed  that  most  stakeholders  view  the 
Governance Regulation  as having set a somewhat ‘revolutionary’ precedent in European 
legislation,  requiring  the  drafting  of  climate  and  energy  plans  in  a  concerted  manner, 
together  with  sub-national  authorities  and  other  relevant  stakeholders.  However,  most 
stakeholders  agreed  that  Member  States  have  yet  to  adequately  reply  to  this  call  for 
cooperation.  Suggested  reasons  include  vague,  non-prescriptive  requirements  in  the 
Governance  Regulations.  According  to  some  national  and  European  authorities,  the 
administrative  structure  of  some  of  the  Member  States  can  hinder  the  process.  For 
example, federal countries such as Belgium or Germany allocate responsibilities to various 
levels  (e.g.  the  final  document  is  at  national  level,  but  consultations  should  happen  at 
regional  level),  making  it  more  difficult  to  comply  with  Article  11.  According  to  another 
national authority, there must be a clear national political will to involve stakeholders in a 
permanent multi-level way. In fact, given the current formulation of Article 11, it is quite 
easy to comply with low levels of effort. Member States that involved stakeholders through 
a multi-level dialogue were very satisfied with the exercise, particularly smaller Member 
States (e.g. Croatia, Lithuania).   

There are diverging views on the quality of the multi-level and multi-stakeholder dialogue 
implemented, suggesting that even where satisfactory dialogue is in place, the reporting 
framework does not allow the processes and their results to be presented in the best way. 
According to the EEB, the level of detail delivered in the reporting is generally low, with 
some Member States not submitting a report on Article 11 (e.g. Slovakia, Sweden).  

5.1.2  Efficiency  

This section synthesises information from the data collection tasks (desk research, survey, 
interviews, CfE, case studies and stakeholder event) on the efficiency of the Governance 
Regulation.  

The efficiency analysis shows mixed results: the Regulation has streamlined some aspects 
of  energy  policy  planning  and  reporting,  but  several  Member  States  noted  increased 
administrative  burdens,  while  others  reported  actual  savings  in  time  and/or  resources. 
However, it is difficult to disentangle the workload created by the Governance Regulation 
from organisational aspects of the national administrations (including limited coordination 
between  those  involved  in  the  reporting  obligations,  the  evolution  of  the  legislative 
framework, and the additional workload imposed by the Regulation – if any – compared to 
reporting  obligations  already  in  place).  Recognised  advantages  of  the  Governance 
Regulation  include  increased  transparency  and  predictability,  better  coordination  and 
cooperation  between  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 Governance Regulation include its 
role in providing a stable framework for clean energy businesses, which is crucial for long-

295  Replies  to  CfE:  Youth  and  Environment  Europe,  Renewables  Grid  Initiative,  Environmental  Justice  Network 
Ireland, Fertő tó Barátai Egyesület. 
296 Reply to CfE: Environmental Justice Network Ireland. 
297 Reply to CfE: Transport and Environment.  

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term investment and development in the sector. Although not yet fully materialised, many 
stakeholders  (especially  national  authorities)  believe  that  the  Governance  Regulation  is 
pushing  national  administrations  to  work  more  closely  together  and  establish  new 
coordination  procedures.  They  also  acknowledged  an  initial  ‘learning  curve’  –  the  first 
reporting  cycles  were  relatively  complex  and  burdensome,  but  the  whole  process  will 
become  easier  and  simpler  over  time,  as  more  reports  are  prepared,  submitted  and 
assessed, the expected content becomes clearer, and more tools and templates are fine-
tuned.  

The evidence showed that the Governance Regulation has partially streamlined 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 short timeframe for strategic decisions in the 
energy  sector  reflected  in  the  NECP  updates,  as  significant  shifts  in  energy  systems 
typically  require  planning  beyond  10  years;  and  the  alignment  of  timetables  for  various 
tasks,  such  as  preparing  the  NECPs  and  Directives  (NEC  Directive)  reporting  prevents 
adequate incorporation of lessons from previous planning cycles, and the overlapping of 
draft  NECP  updates  and  NECPRs  in  2023.  The  yearly  frequency  of  some  reporting 
obligations (especially those under Article 26 on GHG inventory data) strains resources for 
both  Member  States  and  EU  institutions,  suggesting  a  need  for  a  different  (lower) 
frequency of reporting. There are difficulties in synchronisation with other EU obligations, 
such as under 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  coherent  implementation.  Turning  to  international 
obligations, both frameworks on GHG emissions include biennial reporting obligations, but 
on alternate years (even years for UNFCCC/ and odd years for NECPRs) (see section 5.1.3).   

Stakeholders surveyed expressed mixed views on the benefits of common templates and 
platforms, with  equal numbers  of national authorities agreeing and disagreeing that the 
use of information technology (IT) tools led to savings in time and/or resources and more 
efficient planning and reporting. Although the majority of national authorities shared that 
entering  data  on  EU  electronic  platforms  led  to  cost  increases  (e.g.  reformulating  data 
before uploading, lack of an easily sharable tool for authorities within the same country), 
almost  the  same  number  stated  that  the  costs  remained  the  same  or  decreased.  The 
reasons for cost/burden decrease included the fact that the platforms show the information 
and data to be collected and submitted, avoid the need for national tools, and allow multiple 
users to check and validate information, minimising the possibility of errors. The existence 
of  two  separated  platforms  was  criticised,  notably  because  of  the  poor  interlinkages 
between the two, including formats. Nevertheless, stakeholders appreciated the role of the 
two platforms in systematising and standardising data collection, thereby facilitating the 
availability and comparability of information.    

5.1.2.1  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? 

As  stated  in  its  Preamble,  the  Governance  Regulation  sought  to  establish  a  governance 
mechanism resulting in ‘a significant reduction of administrative burden and complexity for 
the  Member  States  and  relevant  stakeholders,  the  Commission  and  other  Union 
institutions’ (Preamble, par. 23). Prior to the introduction of the Regulation, the landscape 
of  EU  energy  policy  was  characterised  by  a  highly  fragmented  system  of  planning  and 

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reporting298. This fragmentation was evident in the existence of numerous obligations, each 
designed for specific aspects of the EU energy policy acquis, leading to inefficiencies and 
inconsistencies. Significant overlaps in reporting duties added to the administrative burden 
on Member States, often involving redundant data submissions to different EU bodies (see 
section 4.1).  

The  lack  of  coherence  in  the  timing  and  intervals  of  these  obligations  compounded  the 
challenge,  making  it  difficult  to  streamline  efforts  effectively299,  while  the  combined 
administrative burdens strained the resources of Member States and the Commission. This 
context  underscored  the  urgent  need  for  a  governance  mechanism  to  simplify  these 
processes, enhance policy coherence and reduce the administrative load, while ensuring 
alignment with the overarching goals of the EU. In this context, and as already reflected 
in the 2016 IA, strong emphasis was given to the objectives of streamlining of planning, 
reporting, and monitoring obligations, and reducing administrative and reporting costs for 
all stakeholders, especially Member States and the Commission 300 (see section 4.1; Annex 
9). 

Evidence from the desk research, public consultation, stakeholder event, and stakeholder 
consultation provides varied opinions on the extent to which the Governance Regulation 
has delivered on its aim to enhance streamlining and coherence (and, thus, its efficiency). 
For  instance,  while  agreeing  on  the  benefits  of  the  Governance  Regulation  for  fulfilling 
obligations  under  the  Paris  Agreement,  experts  from  two  EU  institutions  held  mixed 
opinions  on  its  implementation.  One  interviewee  highlighted  the  importance  of  the 
Governance Regulation in fulfilling obligations under the Paris Agreement, but noted that 
reports sometimes contain irrelevant information, suggesting a need for more focus and 
quantitative  data301.  Conversely,  another  interviewee  acknowledged  potential  synergies 
resulting from integrating planning and reporting processes but cautioned against the risk 
of oversimplification 302. The literature similarly identifies the need for a balance between 
streamlining  processes  and  maintaining  the  quality  and  relevance  of  information 303. 
Feedback from the public consultation reinforced these concerns. Various entities, including 
NGOs and public authorities, echoed the sentiment of increased administrative workload 
due  to  the  Governance  Regulation.  Notably,  entities  like  CAN  Europe,  Eurocities,  and 
ministries  from  Denmark  and  Latvia  raised  specific  concerns  about  the  planning  and 
reporting processes, suggesting that the Regulation has compounded rather than alleviated 
administrative  challenges304.  The  public  consultation  found  that  the  Regulation  imposes 
sometimes  detailed  reporting  obligations  not  directly  linked  to  target  fulfilment.  This 
suggests  simplifying  reporting  by  prioritising  key  indicators  such  as  energy  balance  and 
GHG  emissions,  while  streamlining  and  removing  duplicate  information305.  This  could 
significantly reduce administrative burden and enhance efficiency in reporting processes, 
facilitating interoperability with EU and international reporting tools and alleviating Member 
States' reporting burdens. 

298  Williams,  R.,  Veenstra,  E.,  Rademaekers,  K.,  Svatikova,  K.,  Baroni,  L.,  Fitness  Check  Evaluation  in  the  EU 
Energy  acquis  and  Impact Assessment  of  Planning,  Reporting  and Monitoring for  the  Energy  Union,  Trinomics 
B.V, 2016.  
299 European Commission, Fitness Check Reporting, Planning and Monitoring Obligations in the EU Energy acquis 
Accompanying  the  document  Proposal  for  a  Regulation  of  the  European  Parliament  and  of  the  council  on  the 
Governance of the Energy Union, SWD(2016) final. 
300 Ibid.  
301 Interview with EU institution (1). 
302 Interview with EU institution (1). 
303 Menner, M. and Reichert, G., Governance of the Energy Union: Regulating EU energy and climate policy, 2019. 
304 Reply to CfE: NGOs (2) – CAN Europe & Eurocities; Public Authority (2) Ministry of Climate and Energy (Latvia), 
Danish Ministry of Climate, Energy and Utilities. 
305 Ibid. 

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The survey results provided additional evidence on the Regulation's effects. The survey of 
NCAs  showed  mixed  perceptions  on  cost-efficiencies  (see  Table  14).  While  some 
respondents noted improved coherence in planning and reporting, and better coordination 
between authorities, others did not observe significant changes or experienced challenges. 
Approximately  71 %  of  survey  respondents 306  agreed  that  there  is  higher  coherence  in 
planning and reporting. This opinion was shared by other stakeholder groups. For instance, 
an  interviewee  from  the  third  sector  highlighted  the  benefit  of  consolidating  most 
obligations  into  one  instrument  for  better  visibility  and  understandability.  However,  the 
need for improvement in data submission procedures and for more publicly accessible data 
was  also  noted,  suggesting  that  while  the  Regulation  has  streamlined  some  processes, 
there  is  room  to  enhance  its  efficiency  by  improving  the  user-friendliness  of  data 
collected307.  

Table 14.  Expected benefits of the Governance Regulation  

Source: ICF, based on survey of relevant national authorities. 

Some survey respondents believe that the Governance Regulation has had a negative or 
very negative impact on the costs (38 % of respondents) and the time allocated (55 %) to 
energy  and  climate  planning  and  reporting  (see  Table  15).  This  suggests  that  the 
Regulation may have increased both the financial and time investment in these activities 
for some NCAs in some cases. One interviewee pointed out that despite not incurring major 
financial costs, the Regulation has intensified the workload and responsibilities for a limited 
number  of  staff,  without  an  increase  in  supporting  resources308.  These  observations 
suggest  that  the  organisational  structure  of  national  authorities  has  not  necessarily 
adapted to the stricter cooperation needed to comply with the reporting obligations set by 
the Governance Regulation.  

306 Survey of national authorities: 15/21.  
307 Interview with third sector organisation (1). 
308 Scoping interview with NCA. 

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Table 15.  Changes since adoption of the Governance Regulation (NCAs) 

Source: ICF, based on survey of national authorities. 

During the stakeholder event, participants were polled on whether the Regulation achieves 
an  appropriate  balance  between  the  demand  for  detailed  information  and  a  focus  on 
essentials, while also considering the proportionality of the administrative burden involved 
(see  Figure  31).  Most  stakeholders  felt  that  the  Regulation  could  better  align  its 
administrative demands and benefits. Representatives from NCAs emphasised the inherent 
complexities in the development of NECPs within an ever-evolving regulatory framework. 
Both  the  Polish  and  the  Dutch  NCAs  highlighted  the  critical  need  for  a  more  balanced 
approach to administrative demands versus the level of detail required in NECPs to inform 
investment  decisions  effectively.  The  representative  from  the  Polish  NCA  believed  the 
Regulation  to  require  overly  extensive  documentation,  hindering  stakeholders’  ability  to 
track progress and strategic planning in the NECPs. 

Figure 31. Stakeholder event SLIDO Question 2 poll 

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Source: SLIDO Q3 responses (N=80; average responses: 2.7. Range between 1=Low and 
5=High, e.g. 1 indicates that the Regulation strikes the right balance between the need for 
granular  information  and  a  focus  on  essentials  and  keeping  the  administrative  burden 
proportional to only a very small extent. 

Increased  time  and  investment  are  often  more  justifiable  when  the  data  generated  are 
used effectively. Conversely, incomplete or unused data due to inadequate reporting can 
exacerbate  inefficiencies.  For  instance,  while  projections  that  reporting  would  demand 
substantial time and resources, it yields high-quality datasets crucial for decision-making. 
By  contrast,  reporting  on  the  costs  and  benefits  of  PaMs  is  similarly  intricate  but  less 
utilised, potentially indicating resource constraints.  

The  advantages  of  this  approach  extend  beyond  monetary  gains  –  the  increased 
transparency and predictability, although intangible, hold substantial value, making it cost-
effective  in  the  long  term.  However,  the  streamlining  process  is  continuous  and 
inefficiencies  still  need  to  be  addressed  (e.g.  adaptation  strategies  and  new  methane 
strategies are not integrated). Despite these challenges, some entities anticipate potential 
cost-effectiveness in the future as stakeholders become more familiar with the Regulation's 
processes. The administrative burden is also viewed negatively, with survey respondents 
indicating  a  negative  (38 %)  or  very  negative  (10 %)  impact309.  This  suggests  that  the 
Regulation may have increased the complexity or volume of administrative work involved. 
When asked to provide examples of increased costs, survey respondents suggested that 
the  Regulation  has  led  to  increased  administrative  costs  due  to  additional  reporting 
requirements and lack of coherence with national policy planning. This has resulted in the 
need for parallel planning processes, increased resources, and heightened uncertainty in 
short-term reporting structures. Nevertheless, some national authorities310 have found that 
integrating strategic documents and reporting into a streamlined process with prescribed 
templates has reduced administrative burdens and led to cost savings. The implementation 
of the e-platform has also decreased administrative burden, although quantifying specific 
cost savings remains challenging. Despite measurement difficulties, this unified approach 
has  likely  improved  efficiency,  shown  by  enhanced  interlinkages  between  reporting 
personnel and increased consistency in data usage. 

A notable number of respondents indicated a neutral impact (nine for costs, six for time, 
nine for administrative burden) or did not know/it was not applicable (six for costs, three 
for time, four for administrative burden) in the three categories, suggesting either a lack 
of noticeable change or uncertainty about the Regulation's effects. 

Additional survey data indicate a trend of increased costs in several areas (see Figure 32). 
For instance, 81 % of respondents reported cost increases in preparation and cross-service 
coordination  for  national  plans  and  reports.  Similarly,  81 %  of  respondents  reported 
increased  running  costs  for  coordination  and  data  compilation,  while  89 %  reported 
increased  costs  in  terms  of  the  human  resources  necessary  to  fulfil  obligations.  In  the 
survey, the only area where more than one respondent reported decreased costs was in 
entering data on the EU electronic reporting platform(s) (25 %). These findings suggest 
that, contrary to the Regulation's goals, the administrative burden might not have reduced 
as substantially as expected, or benefits are yet to manifest. However, improved planning 
and reporting processes has been consistent, mirroring Member States' increased climate 
and  energy  ambitions  in  recent  years,  i.e.  not  solely  attributable  to  the  Governance 
Regulation.  The  Regulation's  integrated  planning  approach  has  generated  other 

309 Administrative burden refers to the time, effort and resources required to comply with administrative tasks, 
while costs generally refer to the financial expenses incurred in carrying out activities. While administrative burden 
encompasses both tangible and intangible costs associated with compliance, costs may include a broader range 
of financial outlays beyond administrative tasks (Better Regulation Guidelines, Tool #56). 
310 Survey results: BG, ES, FR, HR, HU, LT, NL, PL.  

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advantages,  such  as  enhanced  policies  and  stakeholder  cooperation,  which  should  be 
recognised in conjunction with broader developments in climate and energy initiatives. 

When  asked  to  provide  examples  of  reduced  cost  and  burdens  resulting  from  the 
implementation of the Regulation, survey respondents noted that integration of multiple 
strategic documents into a single report has streamlined the information gathering process, 
reducing  costs  and  burdens.  The  unified  approach  to  NECPR  reporting  has  improved 
interlinkages between individuals involved in reporting and monitoring, leading to greater 
data consistency and enhancing both the efficiency and quality of the reporting process. 
This was reinforced by NCA and EU institution interviewees. For instance, one interviewee 
shared  their  experience  of  improved  efficiency  in  reporting  due  to  a  more  unified 
platform311, while another noted efficiency gains from the adoption of structured formats 
(Excel tables instead of PDFs), simplifying data management and analysis312. There is an 
expectation  of  future  cost-effectiveness  as  familiarity  with  the  process  improves, 
suggesting potential long-term benefits from these structured reporting methods. 

Several of the representatives from national authorities did not have direct experience of 
the situation before the Governance Regulation. Their answers may simply represent the 
complexities of complying with the different reporting obligations, without appreciating the 
benefits  of  the  Regulation  in  simplifying  the  pre-existing  framework.  The  overlapping  of 
draft  NECP  updates  and  NECPRs  in  2023  may  have  created  a  recency  bias  in  national 
authorities’ answers.  

Figure 32. Associated cost of the Regulation  

Source: ICF, based on survey of national authorities. 

The  evidence  (particularly  case  studies  and  desk  research)  provided  limited  and 
fragmented information on the current costs of implementing the Governance Regulation 
for Member States and the European Commission. The analysis is therefore based on a set 
of assumptions and simplifications and needs to be read with caution (see Annex 3).  

The  analysis  focuses  on  the  direct  compliance  costs  for  national  authorities  in  Member 
States  and  EU  institutions  (including  the  European  Commission  and  agencies)  and 
considers  direct  staff  costs  (annual  recurring  costs  and  one-off  adjustment  costs). 

311 Interview with NCA (1). 
312 Scoping interviews with EU institution (1). 

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Information  is  provided  on  external  costs  (e.g.  consultancies  and  research  institutes 
contracted  by  national  authorities  and/or  the  European  institutions  to  support  them  in 
complying with the different reporting obligations imposed by the Governance Regulation). 
No  evidence  was  collected  on  additional  costs  for  Member  States  attributable  to  the 
implementation  of the  Governance Regulation  (e.g. IT  costs) because none  of the NCAs 
reported on those in any of the consultation activities.  

The analysis of Member State compliance costs included all main planning and reporting 
obligations of the Governance Regulation:  
  NECP (Article 3, Article 4, Annex I); 
  LTSs (Article 15); 
  NECPRs (Article 17, also covering Articles 20-25); 
  Integrated reporting on GHG PaMs and projections (Article 18); 
  National climate change adaptation planning and strategies (Article 19(1);  
  Annual  reporting,  including  reporting  on  oil  stock,  on  offshore  safety  and  GHG 

inventory data (Article 26); 

  Reporting on 2020 targets (Article 27, one-off obligation). 

In  each  case,  the  analysis  included  one-off  costs  and  recurring  costs,  as  well  as  the 
frequency  of  the  obligations.  All  costs  are  reported  on  an  annual  basis.  In  case  of 
multiannual obligations, costs were calculated for the whole cycle and then divided by the 
number of years covered (e.g. the costs for NECPRs were calculated for the whole cycle of 
their preparation and assessment, then divided by two, as they are due every two years). 
The costs are also provided for the whole five years covered by the evaluation (2018-2023) 
to  provide  a  more  accurate  depiction  of  the  order  of  magnitude.  Table  16  presents  an 
overview of the (estimated) direct compliance costs for Member States.   

Table 16.  Overview of costs for NCAs (EUR million) 

Obligation 

Frequency  Yearly basis 

2018-2023 

- 

FTEs 
one-off 
costs  

FTEs 
- 
recurring 
costs 

- 

FTEs 
one-off 
costs  

FTEs 
- 
recurring 
costs 

NECP 

LTS 

NECPR 

Mi
n 

Ma
x 

Min  Ma

x 

Mi
n 

Ma
x 

Min  Ma

5 
Every 
years (draft 
and final) 

2.9  3.7  2.9  3.7  2.9  3.7  14.

4 

Every 
years 

Every 
years 

10 

2.1  2.9  1.0  1.4  2.1  2.9  5.2  7.2 

2 

1.5  1.9  3.7  4.7  1.5  1.9  18.

4 

23.
6 

x 

18.
4 

GHG 
projections 

reporting 

and 

Every 
years 

2 

0.6  0.8  1.4  1.9  0.6  0.8  7.0  9.6 

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National 
plan/strategy 

adaptation 

Every 
years 

2 

0.0  0.0  1.9  3.2  0.0  0.0  9.5  16.

reporting 

(oil 
Annual 
stock,  offshore  safety, 
GHG inventory data)) 

Every year  0.0  0.0  2.9  4.5  0.0  0.0  14.

7 

2 

22.
5 

Reporting 
targets 

TOTAL  

on 

2020 

One-off 

0.8  1.3  0.0  0.0  0.8  1.3  0.0  0.0 

7.8  10.

5 

13.
9 

19.
5 

7.8  10.

5 

69.
3 

97.
4 

Source: ICF calculations based on data collected from NCAs and desk research. Costs were monetised 
using salary data for staff employed in public administration in the EU for 2023 provided by Eurostat 
and applying a 25 % uplift as per recommendations of the Review Scrutiny Board (see Annex 3). 
Data are reported in 2023 prices.  

Note: One-off costs are estimated at approximately 20 % of the recurring costs (annual basis.) 

Preparation  of  the  NECP  represents  the  most  complex  and  resource-intensive  individual 
obligation,  involving  large  numbers  of  staff  from  different  national  authorities  and 
representing approximately 20 % of the recurring costs incurred by NCAs each year. The 
figures vary widely across Member States, depending on the specific circumstances of the 
country,  its  institutional  organisation  (centralised  or  federal  administration)  and  its 
capacity to comply with the pre-existing planning, reporting,  and monitoring  obligations 
before the Governance Regulation. Member States were clustered into three groups based 
on those factors and the three clusters were used for the estimations (see Annex 3). The 
first  cluster  groups  smaller  countries,  with  a  centralised  institutional  organisation  and 
showing a somewhat improving capacity to comply with planning, reporting and monitoring 
obligations over time313. The second cluster includes Member States of medium dimension 
and/or with a devolved or federal institutional organisation, showing a limited capacity to 
comply with planning, reporting and monitoring obligations over time314. The third cluster 
includes  large  countries,  with  different  institutional  organisations,  showing  a  somewhat 
improving  capacity  to  comply  with  planning,  reporting  and  monitoring  obligations  over 
time315.  

The staff involved in the preparation of the NECP ranges from 10-15 full-time equivalent 
staff (FTEs) to 20-25 FTEs per country in each cycle, encompassing both the draft and the 
final version of the report. Of these, only a limited number (5 to 15, in most cases) work 
on the NECP full time, while others participate in the process at different stages (e.g. as 
part  of  working  groups,  providing  specific  information  and  data).  Similarly,  the 
commitment  is  not  constant  throughout  the  full  five  years  of  the  process,  but  becomes 
more intense ahead of specific milestones (e.g. deadline for presenting the draft NECP). 
Overall,  the  effort  to  produce  and  update  the  NECP  amounts  to  an  estimated  EUR  2.9 
million to EUR 3.7 million per year across the EU-27, and to EUR 14.4 million to EUR 18.4 
million  over  the  five  years  of  the  study.  When  considering  the  effort  of  NCAs  to  comply 
with  the  reporting  obligations  and  produce  the  report,  the  national  LTSs  are  also  quite 
resource-intensive, requiring an estimated 8-10 to 15-20 FTEs in each country. Again, not 
all staff work full-time on this obligation – many only participate in some steps. The low 

313 Cluster 1: BG, CY, DK, EE, FI, HR, HU, IE, LT, LU, LV, MT, NL, SI, SK.   
314 Cluster 2: AT, BE, CZ, EL, ES, PL, PT, RO, SE.   
315 Cluster 3: DE, FR, IT.   

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frequency  of  this  obligation  (LTS  are  due  every  10  years)  generates  comparatively  low 
costs for NCAs on a yearly basis (calculated between EUR 1 million and EUR 1.4 million per 
year and between EUR 5.2 million and EUR 7.2 million over the five years of the study, i.e. 
about 7.5 % of the annual compliance costs of Member States).  

NECPRs are resource-intensive obligations, requiring from 6-8 FTEs to 10-12 FTEs in each 
country. Their relative high frequency compared to NECPs and LTSs (due every two years 
while NECPs are updated every five years and LTS are prepared every 10 years) makes 
their costing higher than that of NECPs (EUR 3.7 to EUR 4.7 million yearly across the EU-
27, and EUR 18.4 to EUR 23.6 million in the five years of the study, approx. 25 % of the 
annual compliance costs of Member States).  

GHG reporting and projections under Article 18 of the Regulation are estimated to require 
from 2-3 FTEs to 5-6 FTEs, corresponding to EUR 1.4 million to EUR 1.9 million on a yearly 
basis, and to EUR 7 MILLION to EUR 9.6 million over the five years of the study, i.e. approx. 
10 % of the annual compliance costs of Member States.  

National climate change adaptation planning and strategies under Article 19 are estimated 
to require from 2-5 FTEs to 8-10 FTEs, corresponding to EUR 1.9 million to EUR 3.2 million 
on a yearly basis, and EUR 9.5 million to EUR 16.2 million over the five-year period, i.e. 
approx. 14-16.5 % of the annual compliance costs of Member States.  

Annual reporting obligations on oil stock, offshore safety and GHG inventory data (Article 
26) are also quite resource-intensive. Reporting on oil stocks and offshore safety requires 
less than 1 FTE, while climate data require from 1.5-2.5 FTEs to 3.5 to 4.5 FTEs. Annual 
frequency makes these prominent obligations, corresponding to EUR 2.9 million to EUR 4.5 
million  per  year,  and  EUR  14.4  million  to  EUR  22.5  million  over  the  five  years  of  the 
evaluation,  or  approx.  22 %  of  the  annual  compliance  costs  of  Member  States.  A  lower 
frequency (e.g. every two years) would lower compliance costs, as would streamlining the 
reporting system.  

Finally, the one-off reporting on 2020 targets under Article 27 requires from 2-5 to 8-10 
FTEs, corresponding to EUR 0.8 million to EUR 1.3 million.  

One-off adjustment costs primarily relate to the creation of reporting structures, processes 
and procedures connecting the different competent authorities in each Member States and 
enabling the broad set of data and information to be included in the NECPs, NECPRs, LTSs 
and GHG reporting and projections. These are estimated at between EUR 7.8 million and 
EUR 10.5 million, i.e. about 11 % of the recurring costs incurrent by Member States in the 
five  years  of  the  study.  While  data  and  information  were  already  available  across  the 
different  competent  authorities  and  information  obligations  prior  to  the  Governance 
Regulation, each was produced individually rather than integrated into a broader and more 
complex  document.  Stakeholders  recognise  that  this  process  enables  more  streamlined 
planning and reporting, as well as better coordination and cooperation among NCAs, even 
if it is not yet fully realised. In some cases, the reorganisation of procedures and processes 
among  competent  authorities  was  limited,  as  Member  States  already  had  coordination 
structures and procedures that could be reused and revised to better align with the needs 
of the Governance Regulation (e.g. Denmark). In other cases, the effort needed to redesign 
and  reorganise  the  data  collection  and  reporting  process  to  align  with  the  Governance 
Regulation was noticeable and is ongoing.   

Insufficient data are available to conduct a structured analysis of the external costs for 
Member  States  resulting  from  the  implementation  of  the  Governance  Regulation.  The 
scarcity of evidence on external costs, particularly the extent to which Member States rely 
on consultancies or other external parties to comply with the obligations of the Governance 
Regulation, presents a challenge. While some information was gleaned from case studies, 
it remains limited, with little data on the magnitude of these costs. 

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The case studies reveal that some Member States, such as Germany, Poland and Romania, 
have  received  some  support,  including  contractual  agreements  with  external  entities. 
However, the amounts or duration of these contracts were not disclosed. This information 
gap is partly filled through ICF’s internal trackers316 monitoring projects implemented by 
the  European  Commission’s  Directorate-General  for  Structural  Reform  Support  (DG 
REFORM)  through  procurement  since  July  2019.  These  projects  fall  under  two  EU 
programmes:  the  Technical  Support  Instrument  (TSI),  providing  tailored  technical 
expertise  to  Member  States  to  design  and  implement  reforms  since  2021,  and  its 
predecessor, the Structural Reform Support Programme (SRSP) for 2017-2020. The TSI 
assistance covers various policy areas and the analysis here focuses on projects related to 
the Energy Union, energy, and climate policies, given their relevance to the Governance 
Regulation. This source is used as a proxy for insights into the extent of overall external 
costs This approach has limitations, such as excluding any external cost linked to national 
procurement processes and attributing the full cost to the compliance with the Governance 
Regulation  (in  reality  it  may  be  only  a  component  of  the  overall  project.)  The  values 
available from the tracker represent the maximum value of the contracts, not considering 
possible discounts by the contractors as part of the procurement process. Nevertheless, it 
can  provide  an  indication  of  the  number  of  Member  States  requesting  some  form  of 
external support and the linked costs.   

Information on requests for support from EU Member States was collected in relevant policy 
areas between 2020 and 2023, noting the year,  country, maximum value of the reform 
projects  and  associated  costs.  These  18  projects  indicate  a  diverse  range  of  activities 
targeting  sustainable  growth,  particularly  in  energy  and  climate  sectors,  including 
renewable energy,  energy efficiency, climate adaptation, and policy development across 
different  Member  States.  While  assuming  that  actual  costs  and  project  values  are  likely 
lower, these data provide a foundational understanding. The findings show that: 

About  half  of  the  Member  States  requested  EU  support317.  Belgium,  Croatia,  Estonia, 
Finland,  Greece,  Hungary,  Poland  and  Portugal  participated  in  one  project  each,  while 
Czechia, Ireland, Italy, Latvia, Romania, Slovakia, Slovenia and Spain engaged in multiple 
projects;  

The total value of the 18 relevant projects was EUR 9 million, which could be used as a 
proxy for the external costs across Member States;  

The  average  value  of  such  projects  is  approx.  EUR  500 000318. Individual  project  values 
show notable variation, ranging from EUR 150 000 to EUR 1 million. Larger projects (valued 
between EUR 1 million and EUR 3.7 million)319 typically involve multiple countries, although 
there is an exception where only one country is involved. Interestingly, this exception also 
boasts the longest project duration (26 months);  

The 18 projects have an average duration of about 1.5 years (16.63 months per project), 
ranging from six to 26 months.  

The European institutions (European Commission and its agencies) have also borne costs 
related to the obligations of the Governance Regulation. Table 17 presents an estimation 

316 Two ICF trackers, one from July 2019 to May 2022 (SRSS tracker) and the other from June 2022 to date (DG 
REFORM tracker). 
317 Typically, such support would include a combination of expertise from the European Commission, EU Member 
States’ national administrations, international organisations and/or the private sector to strengthen the capacity 
of  an  EU  Member  State  to  carry  out  reforms  (https://commission.europa.eu/funding-tenders/find-funding/eu-
funding-programmes/technical-support-instrument/technical-support-instrument-tsi_en#howdoesitwork). 
318  Considering all 18 projects, one of which involves 15 countries and is considered an outlier. The outlier value 
is adjusted by calculating a simple average based on 15 countries. The average value across all 19 projects is 
then determined. 
319  The total project value reaches EUR 3.75 million with the involvement of 15 countries, averaging EUR 250 000 
per country.  

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based  on  the  number  of  European  Commission  staff  (FTEs)  working  on  the  different 
obligations,  as  well  as  outsourcing  costs,  based  on  consultations  with  the  European 
Commission’s  DGs  and  agencies  concerned  with  the  implementation  of  the  Governance 
Regulation. All costs are reported on an annual basis. In case of multiannual obligations, 
costs were calculated for the whole cycle and then divided by the number of years covered. 
Costs are also provided for the whole five years of the evaluation (2018-2023) to provide 
a more accurate depiction of the order of magnitude. 

Table 17.  European Commission’s costs (EUR, estimated, 2023 prices)  

Obligation 

Art. 

Frequenc
y 

EU COSTS (TOT)  

One-off 

Recurring 

Recurring 

Over 
period 

the 

on  a  yearly 
basis 

2018-2023 

3, 
Annex I 

4 

Every 
years  

5 

0 

431 500 

2 157 500 

NECPs 

LTSs 

NECPRs 

15 

17 

GHG 
policies 
and projections 

18 

19 

National 
adaptation 
plans 
strategies 

and 

Every  10 
years 

0 

70 300 

351 500 

Every 
years 

Every 
years 

Every 
years 

2 

711 500 

439 375 

2 196 875 

2 

9 

317 250 

1 586 250 

2 

0 

211 500 

1 057 500 

26 

Every year  0 

391 275 

1 956 375 

(oil 

Annual 
reporting 
stocks, 
offshore safety, 
GHG  inventory 
data) 

Reporting 
2020 targets 

on 

17 

EUR 

SO 
(cumulated 
reporting) 

35 

One-off 

352 875 

0 

0 

0 

748 744 

3 743 719 

TOTAL  

1 064 384  3 749 963 

18 749 813 

Source:  ICF,  based  on  data  collected  via  exchanges  with  DGs  ENER  and  CLIMA  and  expert 
assessment. 

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Notes: Total annual costs for staff time are estimated based on the AD7 entry salary for 2023 (EUR 
7 050.14  per  month),  with  a  25 %  uplift  as  per  recommendations  of  Review  Scrutiny  Board  (see 
Annex 3). 

The EU recurring costs related to the implementation of the Governance Regulation amount 
to EUR 3.8 million on a yearly basis, and to EUR 18.5 million across the five years of the 
study. Similar to the Member States, reporting obligations differ for level of complexity and 
frequency, generating different costs for the EU institutions. NECPs and NECPRs are very 
resource-intensive for the EU institutions and represent 11.5 % and 11.7 %, respectively, 
of the yearly recurring costs. Annual reporting under Article 26 represents 10.4 % of the 
annual costs of implementing the Governance Regulation for EU institutions, largely due to 
their  annual  frequency,  and  %  of  the  resources  needed  for  climate  data  (amounting  to 
almost 10 % of the annual implementation costs for EU institutions), compared to reporting 
on oil stocks and offshore safety). The comparative relevance of the resources and costs 
needed to comply with this obligation for EU institutions and Member States could imply 
the need for a revision of the frequency of such reporting. Finally, the reporting obligations 
related to the State of  the Energy Union under Article 35 of the  Governance Regulation 
represent about 20 %  of the implementation costs of the  Governance Regulation  for EU 
institutions. While none of the reporting obligations under Article 35 appears particularly 
complex and resource-intensive, with the possible exception of the subsidies report 320, the 
cumulative effort may imply a need to streamline the many reporting obligations under the 
State of the Energy Union reporting.  

Costs  of  the  set-up  and  expansion  of  the  e-platform  supporting  reporting  under  the 
Governance  Regulations  need  to  be  considered.  The  additional  design  and  development 
costs for EU institutions amounted to EUR 5 million, while the additional maintenance costs 
are quantified at about EUR 750 000 per year (i.e. 15 % of design and development costs).  

These  figures  are  estimates  and  need  to  be  read  cautiously.  The  extent  to  which  the 
information  collected  via  desk  research,  provided  by  stakeholders  during  the  different 
consultation activities, and via the case studies reflects the full range of activities, staff, 
and costs (both internal and  external)  related  to the implementation  of the Governance 
Regulation is unclear. While several parameters have been applied to the data to improve 
the accuracy and robustness of the estimates, they nevertheless remain estimates, with 
an associated degree of uncertainty.  

Similarly,  any  comparison  of  these  figures  with  the  estimated  baseline  costs  and  the 
adoption and implementation of the preferred options included in the 2016 IA321 need to 
be  taken  cautiously.  In  the  IA,  Options  S4  and  S5  (the  closest  to  the  actual  text  of  the 
Governance  Regulation)  were  estimated  to  cost  approx.  EUR  20.1  million  for  Member 
States  on  a  yearly  basis  (recurrent  costs).  This  figure  encompassed  all  types  of  costs  – 
administrative  and  reporting  costs,  ICT/equipment  costs  and  service  outsourcing  costs 
(planning and reporting costs, as well as costs for integrated planning and reporting, are 
sub-components  of  administrative  and  reporting  costs)).  Compared  to  Table  16,  the 
estimates placing the recurring costs for Member States between EUR 13.8 million and EUR 
19.5 million on a yearly basis are higher than those of the 2016 IA, which did not include 
IT and outsourcing costs. However, several factors should be considered when comparing 
the two estimates:  

320 Based on the data collected, the subsidies report alone represents 8.3 % of the implementation costs related 
to the Governance Regulation for EU institutions. 
321    European  Commission,  Impact  Assessment  accompanying  the  document  Proposal  for  a  Regulation  of  the 
European  Parliament  and  the  Council  on  the  Governance  of  the  Energy  Union,  amending  Directive  94/22/EC, 
Directive 98/70/EC, Directive 2009/31/EC, Regulation (EC) No 663/2009, Regulation (EC) No 715/2009, Directive 
2009/73/EC, Council Directive 2009/119/EC, Directive 2010/31/EU, Directive 2012/27/EU, Directive 2013/30/EU 
and  Council  Directive  (EU)  2015/652  and  repealing  Regulation  (EU)  No  525/2013,  SWD(2016)  394  final,  
https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52016SC0394&from=FR 

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Differences between the preferred options included in the 2016 IA and the final text of the 
Governance  Regulation,  where  several  obligations  from  other  pieces  of  legislation  were 
changed due to subsequent revisions and amendments322;  

Evolution of the EU policy and legislative framework, which included developments such as 
the European Green Deal, European Climate Law, Fit for 55 (see section 4.1.2) that were 
not included in the IA analysis and broadened the scope of the Governance Regulation over 
time;  

Difference in prices from 2016 (time of the IA) and 2023. The cumulative inflation rate for 
the 2016-2023 period is calculated at 22.89 %, such that the EUR 20.1 million of annual 
recurrent costs for Member States in 2016 would correspond to EUR 24.7 million in 2023 
prices323. While not necessarily the change in prices if reflected in full in Member States’ 
costs, such differences need to be considered. The IA may also have underestimated the 
implementation  and  compliance  costs  related  to  the  Governance  Regulation  for  both 
Member  States  and  EU  institutions.  A  possible  underestimation  would  reflect  the 
hypothetical nature of every IA, which is subject to many assumptions and conditions. 

The legislative framework relevant to the planning, monitoring and reporting obligations 
set  in  the  Governance  Regulation  is  continuously  evolving.  When  one  of  the  pieces  of 
legislation  whose  reporting  obligations  are  integrated  in  the  Governance  Regulation  is 
amended, the Governance Regulation needs to align the reporting obligations with the new 
needs.  This  implies  additional  work  from  both  the  European  Commission  and  Member 
States to identify the changes, adapt the templates and formats of the reporting, and align 
the  information  collected.  The  legislative  procedures  for  revising  the  EED  and  EPBD  are 
recent examples.  

The literature underscores the Regulation's significant role in providing a stable framework 
for clean energy businesses, which is crucial for long-term investment and development in 
the  sector.  For  instance,  a  report  published  by  E3G  emphasised  the  Regulation's 
contribution  to  bringing  the  Paris  Agreement  mechanisms  into  European  law  and 
guaranteeing the delivery of 2030 energy efficiency and renewable energy targets324. This 
stability  and  predictability  is  essential  for  clean  energy  businesses  to  plan,  invest  and 
innovate  with  confidence.  The  Ecologic  Institute  report,  ‘Charting  a  path  to  net  zero’, 
highlighted how the Regulation ensures coherence and consistency between national and 
EU  climate  and  energy  objectives,  providing  transparency  and  facilitating  cooperation 
among Member States325. These aspects are noted as vital for enhancing policy coherence 
across the EU.  

During the stakeholder event, participants were asked if information included in the NECPs 
on planned and needed investments informed investment decisions, including by private 
operators, and whether NECPs contain information relevant to investors and civil society 
(see  Figure  33).  On  average,  stakeholders  felt  the  NECPs  are  somewhat  informative, 
scoring them three out of five. This suggests that they provide some relevant information 
that supports investment decisions or that they get society involved, but there is scope to 
make the NECPs better and more useful for everyone.  

Inflation 

Eurostat, 

322  Ibid.  
323 
Euro 
explained/index.php?title=Inflation_in_the_euro_area; Inflation tool, https://www.inflationtool.com/euro  
324 
https://www.e3g.org/publications/countdown-to-a-2030-clean-energy-framework/  
325 Velten, E. K., Evans, N., Spasova, D., Duwe, M., de la Vega, R., Duin, L. and Branner, H. Charting a path to 
net zero: An assessment of national long-term strategies in the EU, Ecologic Institute, Berlin, 2022. 

https://ec.europa.eu/eurostat/statistics-

Framework, 

Countdown 

European 

Energy 

2018, 

Clean 

area, 

2030 

E3G, 

the 

to 

in 

a 

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Figure 33. Stakeholder event, SLIDO Question 3 poll 

Source: SLIDO Q4 responses (N=60; average responses = 3. Range between 1=Low and 
5=High. For instance, 1 indicates that the NECPs contain information relevant to investors 
and civil society only to a very small extent). 

At  the  stakeholder  event,  clear  and  actionable  NECP  data  were  highlighted  by  some 
stakeholders  as  crucial  for  investment  decisions326.  Likewise,  detailed  information  on 
implementation schedules, specific indicators for capacity planning, and the harmonisation 
of  information  across  Member  States  were  also  deemed  crucial  for  effective  investment 
planning  and  the  broader  goal  of  achieving  climate  targets.  ECLE  Europe  highlighted 
challenges in understanding the investment specifics at the local level due to unharmonised 
data. They pointed out the need for transparent and granular data to comprehend how EU 
and  local  budgets  will  fund  climate  neutrality  goals,  especially  as  over  100  cities  are 
developing climate city contracts seeking funding. WindEurope acknowledged the value of 
NECPs  for  investors,  highlighting  their  role  in  advancing  net-zero  ambitions  via 
electrification. This was also emphasised by one interviewee, who pointed out the necessity 
for internal integration of processes within governments, emphasising that such integration 
could lead to better outcomes and cost savings in the long term 327. However, the EU may 
have  missed  an  opportunity  to  embed  a  detailed  monitoring  system  that  effectively 
observes  the  transition,  which  is  crucial  for  informed  policy  decisions  and  assessing  the 
Regulation's impact on administrative burden328.  

Determining  whether  or  not  the  benefits  of  the  Regulation  outweigh  its  complexity  and 
costs  is  challenging,  as  reflected  in  the  varied  survey  responses.  For  example,  the 
stakeholder survey of national authorities showed that while some noted improvements in 
the quality and timeliness of information (57 % of respondents),  others did not observe 
significant  changes  or  experienced  challenges.  More  specifically,  57 %  agreed  that  the 
quality and timeliness of information have improved, but 39 % disagreed that there have 
been  savings  in  time  and/or  resources  (see  Table  14).  One  interviewee  provided  an 
example of the financial implications, noting the substantial costs incurred (including the 
need for external consultants and IT system improvements) to comply with the Regulation. 
This  highlights  the  significant  resource  allocation  required  by  some  Member  States  for 
effective implementation329.  

326 Discussions by industry associations (2) and NCA (1).  
327 Interview with third sector institution (1). 
328 Interview with third sector institution (1). 
329 Interview with NCA (LT).  

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5.1.2.2  EQ8.   What is the role played by the electronic reporting platform and/or 

common templates as well as digital technologies? 

According to Article 28  of the Governance Regulation, the European  Commission had to 
establish an online platform (e-platform) to facilitate access to information and cooperation 
among  Member  States  and  to  provide  Member  States  with  a  platform  to  submit  their 
reports. Article 28 requires Member States to use the e-platform for submitting all reports 
referred to in Chapter 4 of the Regulation: 

  Integrated NECPRs (Articles 17, 20-25); 
  Integrated reporting on GHG PaMs and projections (Article 18); 
  Integrated  reporting  on  national  adaptation  actions,  financial  and  technology 
support provided to developing countries and auctioning revenues (Article 19); 
  Annual  reporting  including  information  on  oil  stocks,  offshore  safety  and  GHG 

inventory (Article 26); 

  Reporting on the 2020 targets (Article 27).   

The e-platform consists of two separate systems: ReportNET3, an e-Reporting platform for 
reporting  environmental  and  climate  data  to  the  EEA;  and  the  online  reporting  system, 
ReportENER, which facilitates the collection of energy data and information. The costs for 
the  set-up  and  expansion  of  the  e-platform  supporting  reporting  under  the  Governance 
Regulations  amounted  to  EUR  5  million,  with  additional  maintenance  costs  of  about 
EUR 750 000 per year (i.e. 15 % of design and development costs). NCAs did not report 
specific IT costs related to the alignment of their own IT systems with the EU platforms. 
NCA survey respondents held mixed views on the benefits of using common templates and 
platforms.  When  asked  if  they  believed  that  savings  in  time  and/or  resources 
(rationalisation, use of common templates and IT tools) led to more efficient planning and 
reporting  in  their  Member  States,  nine  out  of  23  replied  positively330,  nine  replied 
negatively331, and five did not know (see Figure 34). 

Figure 34. Contribution  of  rationalisation,  common  templates  and  IT  tools  to  efficient 

planning and reporting (N= 23) 

Source: ICF, based on survey of national authorities. 

Nine out of 23 authorities shared that entering data on EU electronic reporting platform(s) 
led to cost increases332, three noted that costs remained the same333 and four said that 
costs decreased334 (see Figure 35). 

330 Survey of national authorities (9): BG, ES, FR, HR (2), HU, LT, NL, PL.  
331 Survey of national authorities (8): BE, CZ, DK, ES (2), FI (2), LV.  
332 Survey of national authorities (9): BE, CZ, DE, DK, ES (3), LV, MT. 
333 Survey of national authorities (3): FI, HR, SE.  
334 Survey of national authorities (4): BG, HR, HU, LT.  

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Figure 35. Cost  increases  or  savings  linked  to  entering  data  on  EU  electronic  reporting 

platforms (N=23) 

Source: ICF, based on survey of national authorities. 

Potential  reasons  for  cost  increases  and  administrative  burden  were  raised  by  some 
competent authorities during the interviews. Two interviewees pointed out that the word 
limit introduced for some reporting obligations in the platforms requires reformulation of 
the  text,  necessitating  more  time  filling  in  details  on  the  platform  and  a  higher 
administrative burden to approve the newly drafted text335. Two authorities emphasised 
that they had limited time to adapt and familiarise to the new platforms, creating a certain 
(albeit  one-off)  burden 336.  The  repetitive  use  of  these  platforms  should  ensure  greater 
efficiency over time.    

Further  information  on  extra  costs  or  burden  was  provided  by  national  authorities 
responding to the targeted survey. One stated that an example of extra costs or burden 
linked  to  submitting  information  via  the  EU’s  electronic  reporting  platform  was  the 
collection of data across different units and institutions without a tool that could be easily 
sharable 337. Another noted that burden was imposed by the fact that the two platforms are 
poorly  interlinked  and  contained  bugs338.  This  aspect  was  emphasised  by  different 
stakeholders across the different consultation activities.  

Some  stakeholders  reported  cost  savings  and  reduced  burden  linked  to  submitting 
information  via  the  platforms.  One  authority  appreciated  the  platforms  showing  the 
information  and  data  to  be  collected  and  submitted  and  avoiding  the  need  to  develop 
national tools for submission 339. Another authority emphasised that the e-platform allows 
several users to access the information at the same time to check and validate information, 
minimising the possibility of errors340.  

Although  the  limited  number  of  answers  to  the  survey,  compared  to  the  number  of 
stakeholders  who  use  the  platforms  should  be  borne  in  mind,  respondents  have  mixed 
views  about  the  potential  of  the  EU  electronic  platform  to  make  their  reporting  easier. 

335 Interviews with NCAs (2,3).  
336 Interviews with NCAs (3,5). 
337 Survey of national authorities (1): DE.  
338 Survey of national authorities (1): FI.  
339 Survey of national authorities (1): HR. 
340 Survey of national authorities (1): SK.  

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Twelve out of 28 national authorities341 shared that the EU electronic platform made the 
reporting  easier,  but  five  out  of  28  disagreed342  and  three  strongly  disagreed343.  In  the 
case  study  on  Belgium,  one  stakeholder  shared  that  ReportNET3  is  perceived  as  an 
improvement from the previous version, but there is still room to simplify ReportENER344. 
Another NCA interviewed for the case study on France shared that certain features of both 
platforms can be improved, notably the difficulties in importing data to the platforms and 
data  visualisation  when  exporting.  The  review  of  data,  including  proofreading,  on  the 
platforms was sometimes difficult and time-consuming345. The policy officers interviewed 
suggested  improving  the  ergonomics  of  the  platforms,  especially  for  importing  and 
reporting  data,  and  making  the  review  of  data  easier.  Third  sector  organisations 
interviewed  for  the  case  study,  where  aware  of  the  ReportNET  platform,  did  not  find  it 
user-friendly346.  Similarly,  authorities  interviewed  for  the  case  study  on  Poland  felt  that 
ReportNET should be made more cohesive and intuitive by providing clear guidance347. In 
the case study on Romania, the national authorities interviewed were very satisfied with 
the support offered by the European Commission and the EEA in response to requests for 
support with technical issues with the platforms (short tutorials with guidance on how to 
use  the  platforms  were  deemed  particularly  useful)348.  In  their  experience,  ReportNET3 
was  more  difficult  to  use,  particularly  when  uploading  files,  with  frequent  crashes  that 
required data to be entered multiple times 349.  

About one-third (nine  out of 27)  respondents  agreed350 and two  strongly agreed351 that 
authorities in their Member State had to revise internal tools and procedures as a result of 
the adoption of an EU electronic platform (see Figure 36). However, five disagreed 352 and 
two  strongly  disagreed353.  Consequently,  many  of  the  respondents  either  disagreed  (10 
out of 28)354 or strongly disagreed (five out of 28)355 that the platform has saved Member 
States the costs of introducing or maintaining a similar reporting platform at national level. 
Among  the  Member  States  that  disagreed  or  strongly  disagreed,  most  (e.g.  Austria, 
Belgium, Denmark, Finland, Latvia, Lithuania, the Netherlands, Spain) were above the EU 
average  for  ‘overall  e-government  maturity’  according  to  the  e-government  benchmark 
2023 report356. However, in the absence of major revamp of the EU electronic platforms, 
no  major  revisions  of  Member  States’  internal  tools  and  procedures  is  expected  to  be 
needed in the coming years.  

341 Survey of national authorities who replied ‘strongly agree or agree’ (11): BG, CZ, DE, ES (2), FR, HR, HU, LT, 
NL, SE.   
342 Survey of national authorities (5): DE, DK, ES, LV, PL.  
343 Survey of national authorities (3): AT, BE, FI.  
344 Case study: BE.  
345 Case study: FR.  
346 Ibid. 
347 Case study: PL.  
348 Case study: RO. 
349 Ibid. 
350 Survey of national authorities (8): AT, CZ, DE, ES, HR, LT, MT, NL, SK.  
351 Survey of national authorities (2): ES, LV.  
352 Survey of national authorities (5): DE, DK, ES, FI, PL.  
353 Survey of national authorities (2): DE, HR.  
354 Survey of national authorities (9): AT, CZ, DE, DK, ES, HR, LT, LV, NL.   
355 Survey of national authorities (5): BE, DE (2), ES, FI.  
356 European Commission, E-Government Benchmark 2023 – Insight Report, 2023 (EU average was 70 points). 

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Figure 36. Reporting platforms (N=28) 

Source: ICF, based on survey of national authorities. 

Stakeholders  raised  a  concern  about  the  efficiency  of  the  reporting  platforms  used  for 
Member States’ submissions, with the division into ReportNET3 and ReportENER garnering 
some  criticism.  Some  national  authorities  interviewed  emphasised  that  the  existence  of 
the two platforms makes their work more difficult, as it requires more time to understand 
the platform to which data should be reported and does not allow full visualisation of the 
information  provided357.  This  suggests  non-alignment  with  the  digital-ready  policy 
recommendations,  in  particular  Recommendation  1  on  ‘User-centric  processes  ready  for 
automation’, insofar as reporters are required to adapt to different reporting formats and 
platforms’ requirements.  

Two  interviewees  from  the  third  sector  noted  that  the  two  platforms  scatter  the 
information, making the systems less user-friendly358. The use of two reporting platforms 
was  critiqued  by  another  interviewee,  who  stressed  the  potential  redundancy  in 
maintaining  two  platforms359.  This  perception  was  reflected  in  the  CfE  and  public 
consultation 360: one interviewee noted  some initial challenges using the platform due to 
validation  checks,  although  they  acknowledged  that  the  platform  simplified  reporting  in 
some areas (e.g. climate finance)361.  

One  interviewee  emphasised  the  platform's  role  in  standardising  reporting,  making  it 
unnecessary  for  each  Member  State  to  develop  independent  systems362.  It  thus 
transformed  unstructured  information,  often  in  PDF  format,  into  accessible,  structured 

357 Interviews with national authorities (3,4,5). 
358 Interview with the third sector (2,5). 
359 Scoping interview with NCA. 
360 Replies to CfE: Public authority – Ministry for the Ecological Transition and the Demographic Challenge (EE); 
NGO – CAN Europe. 
361 Scoping interview with NCA. 
362 Scoping interview with EU institution. 

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data363,  which  two  interviewees  from  the  third  sector  noted  made  information  easy  to 
access 364. It also enables economies of scale, as well as availability and comparability of 
information.  However,  three  other  interviewees  from  the  third  sector  shared  that  the 
information  provided  is  not  easily  understandable365.  They  reported  difficulties  with  the 
readability  of  downloaded  information,  which  was  fragmented  and  not  accessible  to  the 
general  public  (overly  complex).  One  of  these  three  stakeholders  suggested  that 
information  could  be  provided  in  a  more  understandable  manner,  for  instance  by 
systematising information received from the different Member States, or by providing the 
information in a comparative fashion.   

5.1.2.3  EQ9  -  To  what  extent  has  the  Regulation  contributed  to  streamlined 
further 

reporting,  and  monitoring 

including 

through 

planning, 
digitalisation or consolidation?  

Responses to the targeted survey indicate a divided perspective among NCAs. Nine out of 
25366 agreed that the timing of different obligations within the Governance Regulation is 
consistent and reasonable, while 11 disagreed (six disagreed, five strongly disagreed) (see 
Figure  37).  Similarly,  on  alignment  with  Member  State  obligations,  10  out  of  26 
respondents agreed and 12 disagreed (eight disagreed, four strongly disagreed). Feedback 
from one stakeholder described the initial phase of drafting the NECPs as challenging, but 
they  anticipate  more  fluidity  in  the  future367.  The  skills  and  structures  have  now  been 
established  and  this  is  likely  to  make  reporting  more  cost-effective.  Evidence  from  the 
public consultation highlighted some issues with reporting. One stakeholder noted that the 
finalisation of the reporting guidelines and the commissioning of the reporting platforms 
occurred  very  close  to  the  reporting  deadline368.  They  urged  consideration  of  this  point 
when identifying potential reporting gaps and emphasised the need for both the guidelines 
and  access  to  the  platform  to  be  available  earlier.  Although  a  specific  timeline  was  not 
provided, it was suggested to consider time needed for implementors to test and provide 
hands-on  training  with  the  system  before  implementation,  which  would  also  reduce 
pressure on Commission staff to respond to queries.  

363 European Commission, Reporting system for EU countries. 
364 Interviews with third sector stakeholders (). 
365 Ibid. 
366 Survey of national authorities (8): BG, CY, CZ, DE, FR, HR, NL, SK.  
367 Scoping interview with EU institution. 
368 Reply to CfE: Public authority – Ministry for the Ecological Transition and the Demographic Challenge (EE). 

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Figure 37. National authorities’ views on timing and periodicity of planning and reporting 

Source: ICF, based on survey of national authorities. 

The  survey  data  provide  insight  into  stakeholders'  perceptions  of  the  Governance 
Regulation's  alignment  with  EU  and  international  reporting  obligations.  Of  the  26 
respondents  from  national  authorities,  10  agreed  that  the  timing  is  consistent  and 
reasonable,  while  nine  disagreed  (seven  disagreed,  two  strongly  disagreed),  indicating 
considerable  difference  of  opinion  within  the  EU  context.  Seven  respondents  remained 
neutral,  suggesting  either  uncertainty  or  insufficient  knowledge.  In  terms  of  the 
Regulation's alignment with international obligations, the data from 24 respondents skew 
more positively, with 13 agreeing that the timing aligns well with international reporting 
frameworks.  However,  eight  respondents  disagreed  (six  disagreed,  two  strongly 
disagreed),  revealing  concerns  about  international  consistency  among  a  significant 
minority.  Only  three  respondents  were  neutral  on  this  matter,  implying  a  more  decisive 
viewpoint on international alignment compared to EU obligations. 

When  asked  about  challenges  with  the  timing  of  obligations  within  the  Governance 
Regulation, stakeholders voiced several concerns. Firstly, they noted that the prescribed 
five-year  timeframe  for  strategic  decisions  in  the  energy  sector  often  falls  short,  as 
significant shifts in energy systems typically require longer-term planning (except in cases 
of  geopolitical  changes).  Secondly,  stakeholders  highlighted  difficulties  in  aligning  the 
timetables  for  various  tasks,  such  as  preparing  the  NECPs  and  NEC  Directive  reporting, 
preventing  adequate  integration  of  lessons  from  previous  planning  cycles.  Stakeholders 
pointed to the resource-intensive nature of reporting and updating NECPs, with overlapping 
responsibilities straining human resources. They also raised concerns about close deadlines 
between NECPRs and NECP review processes, leading to workload challenges. The fact that 
key amendments to legislation linked to the Governance Regulation was negotiated and 
adopted  shortly  before  the  update  of  the  NECPs  was  noted  as  a  barrier  to  fulfilling 
obligations under the Regulation. Stakeholders highlighted data utilisation challenges and 
concerns  about  regulatory  integrity  due  to  infrequent  updates  to  the  Governance 
Regulation,  which  could  lead  to  misinterpretation  and  incorrect  implementation  of 
definitions. Further concerns were the timing and sequencing of reporting obligations, such 
as the overlapping of draft NECP updates and NECPRs in 2023, and the legislative process 
of the Fit for 55 package, which created additional workload and uncertainties about what 
needed to be taken into account in preparing the draft NECP update. The sequencing of 
GHG inventory data, projections, and NECP update  reporting  all have  a March deadline. 

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However, some national authorities observed that it would be more logical to have projects 
following the energy data, and the  NECP updates following both. Such order would also 
simplify the work of national authorities. Similarly, some national authorities considered 
that the LTSs should precede the medium-term plans of the NECPs and their updates.  

When  asked  about  the  alignment  of  obligations  within  the  Governance  Regulation  with 
other  national,  EU  or  international  obligations,  stakeholders  pointed  out  several 
discrepancies.  For  example,  one  national  authority  (Croatia)  noted  that  the  timing  of 
obligations in the case of Directive (EU) 2016/2284 on the reduction of national emissions 
of  certain  atmospheric  pollutants  is  not  aligned  with  Governance  Regulation.  Another 
national  authority  (Spain)  explained  that  conflicts  arise  with  other  national  reporting 
requirements, such as those stemming from the national air pollution control programmes 
under the NEC Directive (see section 5.1.3).   

Despite mixed perceptions of the consistency of the Governance Regulation and alignment 
with other obligations, there appeared to be a stronger sentiment that the timing aligns 
better with international than EU obligations.  

Interviews with third sector representatives and NCAs echoed these survey findings. Two 
third sector interviewees highlighted sequencing issues within the Governance Regulation, 
particularly the timing of submissions and the connection between processes such as target 
setting and progress assessment, which can lead to information gaps and outdated plans, 
especially during government transitions 369. Other third sector interviewees reinforced this 
perspective,  emphasising  that  digital  templates  have  improved  data  access  and 
comparability,  but  data  quality  and  granularity  vary  widely  between  Member  States, 
hindering full harmonisation370. The perceived difficulty in accessing NECPRs compared to 
the more readily available NECPs complicates streamlined monitoring 371. 

One NCA interviewee suggested that integrating EU and international reporting cycles could 
reduce the administrative burden resulting from misalignment, allowing Member States to 
fulfil their obligations more effectively372. Another recommended that the frequency and 
timing  of  reviews  and  reports  be  reconsidered,  considering  the  dynamic  nature  of  the 
Regulation's objectives. As these decisions have long-term implications, establishing a task 
force  for  regular  meetings  to  discuss  NECPs  would  enhance  the  effectiveness  of  the 
regulatory process and maintain relevance in the face of policy shifts and administrative 
changes373.  These  proposals  correspond  with  the  survey  respondents'  calls  for  better 
alignment  and  reflect  a  shared  desire  for  more  dynamic  and  responsive  planning  and 
reporting mechanisms. 

While the Regulation has laid the groundwork for more streamlined planning, reporting and 
monitoring  through  the  introduction  of  digital  templates  and  structured  processes,  its 
contribution  is  varied.  Stakeholder  feedback  and  survey  responses  suggest  that 
inconsistencies in data quality, access to information, and alignment with existing EU and 
international  obligations  present  ongoing  challenges  that  impede  the  full  realisation  of 
streamlined  operations.  Despite  progress,  especially  in  digitalisation,  the  Regulation's 
impact  on  streamlining  is  only  partial,  implying  a  need  for  continued  refinement  and 
adaptation to achieve its intended goals. 

369 Interview with third sector (EEB). 
370 Interview with third sector (E3G). 
371 Interview with third sector (1). 
372 Interview with NCA (1). 
373 Interview with NCA (1). 

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5.1.3  Coherence  

This section synthesises information from the desk research, CfE, surveys, interviews and 
stakeholder event on the internal coherence of the Governance Regulation (EQ10) and its 
external coherence with other EU and international obligations (EQ11). 

  Internal  coherence  is  between  the  different  planning/monitoring/reporting 
processes  and  related  timeframes  under  the  Governance  Regulation.  As  a  key 
objective of the Regulation, it raises practical aspects: internal timeline, definitions, 
reporting  templates  and  guidelines.  Important  internal  coherence  issues  include 
possible  duplications  and  contradictions,  and  coverage  and  (im)balances  among 
fields of policy intervention. 

  External  coherence  is  between  the  Governance  Regulation  and  the  broader  EU 
policy  framework  (notably  the  European  Green  Deal  and  its  derived  policies  and 
regulations)  and  with  relevant  international  policy  frameworks  (especially  the 
UNFCCC  and  Paris  Agreement).  A  high  level  of  coherence  offers  potential  for 
synergies. This also raises practical aspects, particularly in the timing of reporting 
obligations. A major issue is the challenge to maintain external coherence over time 
while the international  context and the EU policy  framework are changing rapidly 
compared to the process initially planned at the time of adoption of the Regulation 
(end  2018).  External  coherence  may  have  strong  links  with  EQ6,  on  multi-
stakeholder dialogue (coherence between local, regional, and national level can be 
seen as multi-level coherence). 

Overall,  evidence  from  the  stakeholder  consultations  indicates  that  the  Governance 
Regulation streamlined previous planning and reporting obligations from various pieces of 
legislation across energy, climate, and other Energy Union-related policy areas. However, 
stakeholders highlighted some inconsistencies in both the internal (between the NECPs and 
LTSs) and external (especially with the European Climate Law, the Paris Agreement and 
UNFCCC) coherence of the Governance Regulation.  

In respect of internal and external coherence, the Governance Regulation needs to find the 
right balance between: 

  Providing  an  integrated  and  comprehensive  view,  covering  and  structuring  all 

interactions so as to create synergies and effectiveness gains; and 

  Creating peak loads in reporting efforts, with considerable complexity, difficulties in 
setting  a  timeline  that  meets  all  purposes,  challenges  to  maintain  an  umbrella 
planning/monitoring/reporting framework (given that it is connected to many pieces 
of legislation). 

In  practice,  the  Governance  Regulation  and  the  related  Implementing  Regulation, 
guidelines and guidance are living documents that can support an iterative and learning-
by-doing  process.  None  of  the  stakeholders  consulted  criticised  the  principles  of  the 
Governance Regulation or its general contribution to improving coherence in energy and 
climate policies. Whether explicitly or implicitly, most of the comments acknowledge the 
challenge of ensuring coherence in a broad and complex framework and make suggestions 
to correct possible flaws or fine-tune practical aspects (particularly the timeline).  

The  Governance  Regulation  was  strongly  identified  by  stakeholders  as  an  umbrella 
planning/monitoring/reporting framework, indicating successful coherence.  

EQ10 - To what extent does the harmonised and integrated nature of planning, 
reporting,  and  monitoring  obligations  lead  to  improved  coherence  of  Member 
States  and  EU  climate  and  energy  policy  within  the  remit  of  the  Regulation? 
(internal coherence) 

The majority of stakeholders acknowledged that the Governance Regulation has improved 
coherence between Member State and EU climate and energy policies. Nevertheless, there 
are still some inconsistencies, largely due to the complexity of integrating many obligations 

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in  a  single  framework  and  the  many  changes  that  have  occurred  since  the  Governance 
Regulation was adopted in December 2018. The following general conclusions can be drawn 
from the evidence: 

A  large  majority  of  stakeholders  believe  the  Governance  Regulation  to  be  internally 
coherent and to provide a single framework to gather the various planning, monitoring and 
reporting  due  from  the  Member  States.  Evidence  also  indicates  that  the  Regulation 
streamlined previous planning and reporting obligations from various pieces of legislation 
across energy, climate, and other related policy areas (see EQ1 and EQ2); 

Some evidence suggests that coherence is lacking between the reporting obligations of the 
Governance  Regulation,  particularly  between  NECPs  and  LTSs,  in  relation  to  both  the 
process and the timeline;  

There is room to improve coherence between the overall picture/structure (provides the 
strategic  view  for  integration)  and  the  many  practical  details  (enables  coherent 
implementation), particularly in relation to coverage, interactions and timelines;  

A  better  balance  between  the  dimensions  and  topics  could  help  to  avoid  bias  in 
prioritisation.  However,  it  is  not  always  clear  whether  this  would  be  a  matter  for  the 
Governance Regulation or for related legislation (e.g. requirements related to adaptation); 

Coherence issues also derive from the challenge of keeping the Governance Regulation up-
to-date. 

The  Governance  Regulation  covers  three  types  of  obligations:  planning,  reporting  and 
monitoring.  

The  Commission’s proposal for the Governance Regulation highlighted that the planning 
and reporting requirements in place at the time provided detailed information on specific 
policy areas to support sectoral legislation, but were spread in ‘a wide range of separate 
pieces  of  legislation  adopted  at  different  points  in  time,  which  has  led  to  certain 
redundancy, incoherence and overlaps and lacking integration between energy and climate 
areas’374. The Regulation  thus sought to bring together the previous ‘scattered planning 
and  reporting  obligations  from  the  main  pieces  of  EU  legislation  across  energy,  climate, 
and other Energy Union related policy areas and thereby achieve a major simplification of 
obligations’375. In total, the Regulation integrated, streamlined or repealed more than 50 
individual planning, reporting and monitoring obligations of the energy and climate acquis 
(integrating  31  and  deleting  23).  It  also  introduced  new  requirements,  notably  the 
introduction  of  NECPs,  and  emphasised  several  cross-cutting  issues  (e.g.  EEF  principle, 
energy  poverty).  The  Governance  Regulation  also  translated  an  invitation  in  the  Paris 
Agreement to prepare long-term climate strategies by 2020 into a binding obligation under 
EU law for the Member States and the Commission to prepare LTSs.  

The overall structure of the Governance Regulation is designed to effectively present the 
Energy Union’s dimensions, with provisions sequentially addressing different targets and 
dimensions. The structure of the templates used for the NECPs or NECPRs aligns with the 
goal of facilitating a unified reporting process for both planning and progress evaluation. 

374  Proposal for  a  Regulation  of the  European  Parliament  and  of  the  Council  on  the  Governance  of  the  Energy 
Union, amending Directive 94/22/EC, Directive 98/70/EC, Directive 2009/31/EC, Regulation (EC) No 663/2009, 
Regulation (EC)  No  715/2009,  Directive  2009/73/EC,  Council Directive  2009/119/EC,  Directive  2010/31/EU, 
Directive 2012/27/EU, Directive 2013/30/EU and Council Directive (EU) 2015/652 and repealing Regulation (EU) 
https://eur-lex.europa.eu/legal-
No 
content/EN/TXT/?uri=COM:2016:759:REV1  

COM/2016/0759 

525/2013, 

2016/037, 

final/2 

- 

375 Ibid. 

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Figure 38.  Overview  of the main  planning and reporting components  of the Governance 

Regulation 

Source: ICF elaboration. 

This section analyses how the internal coherence of the Governance Regulation is perceived 
by stakeholders and the specific coherence issues that have been identified. It reviews the 
coherence of the components of the Regulation, primarily between NECPs and LTSs, and 
within  its  overall  timelines.  It  also  analyses  potential  overlaps,  duplications  and 
contradictions within the Governance Regulation. Coherence issues in the practical aspects 
of the Regulation (e.g. templates and guidelines) are also covered. Finally, the topics of 
energy  poverty  and  the  EEF  principle  are  examined  to  illustrate  how  the  Governance 
Regulation  can  contribute  to  improved  coherence  in  EU  and  Member  State  legislation, 
planning and reporting. 

As shown in Figure 38, national authorities had somewhat mixed views about the internal 
coherence of the Governance Regulation: 

  Overall,  a  majority  of  respondents  (42-55 %)  agreed  with  the  three  statements 
about internal coherence, while about 20-30 % disagreed. Agreement was strongest 
for  overall  coherence  (55 %,  compared  to  21 %  disagreement).  The  strongest 
disagreement (32 %, including two that strongly disagreed) concerned the overlap 
or duplication of obligations; 

  Just over half (16 out of 29) of the national authorities agreed376 that the planning 
and reporting obligations in the Governance Regulation are coherent overall, while 
only  six  disagreed 377.  No  respondent  strongly  agreed  or  strongly  disagreed, 
indicating that views on overall coherence are moderate; 

  12 out of 28 national authorities agreed378 that there are no contradictions between 
planning and/or reporting obligations contained in the Governance Regulation, while 

376 BG (1), CY (1), CZ (1), DE (1), DK (1), ES (2), FI (1), FR (1), HR (1), HU (1), LT (1), MT (1), NL (1), SE (1), 
SK (1).  
377 BE (1), ES (1), DE (1), FI (1), PL (2).  
378 BG (1), CY (1), CZ (1), ES (3), FI (1), FR (1), HR (1), HU (1), NL (1), SK (1).  

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only six disagreed379. Again, moderate views were evident from the lack of strongly 
agree/strongly disagree responses;  

  Just under half (13 out of 29) of the national authorities agreed that there are no 
overlaps  or  duplications  between  the  planning  and/or  reporting  obligations 
contained in the Governance Regulation380, while nine disagreed (seven disagreed 381 
and  two  strongly  disagreed382).  The  views  on  this  issue  were  the  most  balanced, 
featuring  the  only  two  'strong'  opinions  among  the  responses  to  the  three 
statements on internal coherence. 

Figure 39. Survey respondents’ views on the Governance Regulation’s internal coherence 

Source: ICF, based on survey of national authorities383. 

Further context was provided in the open survey questions and interviews, as described 
below.  However,  as  improving  coherence  in  EU  energy  and  climate  policy  is  one  of  the 
objectives  of  the  Governance  Regulation,  stakeholders’  feedback  on  issues  or  areas  for 
improvement concerning coherence is also linked to the effectiveness evaluation criterion. 
This section summarises stakeholders’ answers to the evaluation questions on coherence, 
some of which confirm the analysis of effectiveness (see section 5.1.1). 

On  the  overall  coherence  of  planning  and  reporting  obligations,  13  stakeholders 384 
explained  that  the  Governance  Regulation  created  a  single  framework  that  integrates 
requirements (e.g. planning processes, monitoring systems, information to be  reported) 
for Member States to comply with all of their obligations related to EU energy and climate 
policy. Notably, the introduction of NECPs and NECPRs streamlined EU-level requirements 
for climate and energy planning and reporting.  

379 FI (1), LT (1), MT (1), PL (1), SE (2). 
380 BG (1), CY (1), CZ (1), DE (1), DK (2), ES (3HR (1), HU (1), NL (1), SK (1). 
381 DE (1), FI (1), LT (1), MT (1), PL (1), SE (2). 
382 BE (1), FI (1). 
383 Answers from 18 Member States: BE (1), BG (1), CY (1), CZ (1), DE (4), DK (2), ES (3), FI (2), FR (1), HR 
(2), HU (1), LV (1), LT (1), MT (1), NL (1), PL (3), SK (1), SE (2). 
384 Replies to CfE: Business associations (2): COGEN Europe; European Renewable Energies Federation. NGOs 
(2): Transport and Environment; Environmental Justice Network Ireland (EJNI). Academic/Research Institute (1): 
Brussels School of Governance (VUB). Other (1): The Coalition for Energy Savings. Seven scoping interviews with 
EU institutions (3), EU Agency (1), NGO (1), NCA (2). 

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Answers  from  six  stakeholders 385  highlighted  that  having  a  single  framework  helps  to 
reduce siloed approaches, with better integration of policies 386 and aggregation of targets 
and policies387. The Governance Regulation sets clear and aligned processes for each time 
horizon,  from  yearly  reporting  to  long-term  planning  (30  years),  covering  all  of  the 
dimensions  and  policy  areas  of  EU  energy  and  climate  policy  and  stimulating  enhanced 
cooperation  among  different  ministries  at  national 388  and  EU  level389.  The  NECPs  also 
provide  an  opportunity  to  identify  possible  misalignments  of  dimensions/topics  and  to 
assess  whether  they  form  a  coherent  whole.  Similarly,  mandatory  templates  increase 
comparability, which is especially helpful for benchmarking390. 

Three stakeholders 391 reported that implementing the Governance Regulation has helped 
to  improve  consistency  in  national  data  by  aligning  national  data  collection  with  the 
Regulation,  as  well  as  better  implementation  of  reporting.  However,  despite  a  similar 
structure in reporting (templates), there was significant variation in Member States’ level 
of detail and complexity of reporting 392. For example, although the template for the NECPs 
ensures  that  all  Member  States  provide  minimum  data  about  their  scenarios,  those 
scenarios are explained with different levels of detail. Some NECPs include more data than 
others  (e.g.  multiple  impacts).  Similarly,  data  on  investments  and  financing  needs  vary 
significantly, meaning that stakeholders (e.g. investors) have access to different levels of 
information in different countries.  

NECPs were sometimes ‘a compilation of existing plans’, suggesting a lack of meaningful 
integration  (see  EQ1  and  EQ2).  Some  also  perceived  the  NECP  as  merely  a  reporting 
obligation,  rather  than  an  opportunity  for  more  interaction  between  the  various  units 
involved in compiling the NECP. The integration of the five Energy Union dimensions can 
be  seen  as  a  progressive  approach.  The  previous  separate  reporting  processes  already 
supported more integrated and strategic planning, monitoring and reporting of the main 
energy  and  climate  targets  (reducing  GHG  emissions,  developing  RES  and  improving 
energy efficiency). A 2022 study393 analysed the experience gained and improvements in 
the planning, monitoring and reporting of energy efficiency policies since the first NEEAPs 
in 2007-2008 until 2020 and the switch to the Governance Regulation process. The same 

385 Scoping interviews with EU institutions (2), NCAs (CZ, DK); Interviews with third sector organisations (2). 
386 For example, the NECP template includes dedicated sections on energy poverty, where Member States must 
report how they assess energy poverty, and their strategy and policy measures to tackle it. This usually implies 
coordination between social, energy market and energy efficiency policies. 
387 Chapter 2 of the NECP template relates to objectives and targets, followed by chapter 3, on PaMs in place or 
planned to achieve the targets. Section B is about the scenarios and IAs of the PaMs, which, in theory, should 
verify  that  the  aggregation  of  expected  impacts  would  enable  meeting  the  umbrella  targets,  particularly  the 
reduction in GHG emissions. 
388  Completing  the reporting  for  the  NECPR,  NECP  and  LTS  requires  that  the  different  ministries  (e.g. energy, 
industry,  transport,  construction,  R&I)  and  even  the different  units  within  a  ministry  (e.g. Ministry  of  Energy: 
units  in  charge  energy  supply,  units  in  charge  of  energy  markets,  units  in  charge  of  energy  efficiency),  and 
possibly other public bodies (e.g. national energy agency, energy regulatory body; body in charge of the national 
GHG  emission  inventory)  coordinate  to  follow  the  same  timeline,  use  the  same  underlying  scenarios  and 
assumptions, etc. 
389 All Member States must provide planning data about the same target year (e.g. 2030) by the same deadline. 
This creates more favourable conditions for EU-wide assessment and regional cooperation among neighbouring 
countries, compared to a situation where information is available from national processes only (different points 
in time, different time horizons) (see EQ5).  
390  Interviews  with  EU  institution  (1)  and  third  sector  organisations  (3).  For  example,  the  NECPR  defines  the 
indicators and metrics that Member States must use to report their data. This makes it easier for Member States 
to compare with each other, and for third sector organisations or European projects or studies to make cross-
country  comparisons,  thereby  identifying  good  practices  (or  gaps)  that  can  be  used  to  support  experience-
sharing. 
391 Scoping interview with NCAs (BE, DK) and EU institution (1). 
392 Interviews with third sector organisations (2).  
393 Economidou, M., Ringel, M., Valentova, M., Castellazzi, L., Zancanella, P., Zangheri, P., Serrenho, T., Paci, D. 
and Bertoldi, P., ‘Strategic energy and climate policy planning : Lessons learned from European energy efficiency 
policies’, Energy Policy, Vol. 171, 2022, 113225. https://doi.org/10.1016/j.enpol.2022.113225 

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trajectory can be expected with the NECPs: the first round has diverse degrees and forms 
of  integration  or  juxtaposition  among  Member  States,  with  subsequent  rounds  showing 
more convergence towards higher integration. The NEEAPs initially focused on complying 
with the reporting obligations, then progressively moved towards using the NEEAPs as a 
policy  planning  tool.  Importantly,  the  2022  study  showed  that  the  improvements  in 
Member States’ use of NEEAPs were partly driven by the new provisions introduced by the 
EED in 2012 and its amendments in 2018.  

In the current context, this means that the Governance Regulation can provide the general 
framework for integration and coherence, but the actual achievement of better integration 
and coherence depends on the evolution of related legislation. For example, the EED recast 
requires  the  comprehensive  heating  and  cooling  assessment  (Article  25(1)  EED)  to  be 
accompanied  by  the  assessment  of  RES  potentials  (previous  Article  15(7)  of  RED).  This 
explicitly  requires  integration  on  heating  and  cooling  supply  related  to  RES  and  energy 
efficiency, with the umbrella objective to decarbonise heating and cooling. Such integration 
is facilitated by the joint revision of the main pieces of energy and climate legislation (first 
done with the Clean Energy for All Europeans package in 2016-2018, and more recently 
with the Fit for 55 package). 

The Governance Regulation sets an iterative process for the NECPs: for each round, the 
Member States first submit a draft, which is assessed by the Commission. The Commission 
then makes individual recommendations to each Member State before they submit their 
final NECPs. This can accelerate the learning phase initiated at the end of 2018 with the 
adoption of the Governance Regulation, and in early 2019 with the submission of the first 
draft NECPs. Such progress can be seen when comparing the successive assessments by 
the Commission of the draft NECPs, NECPs and draft updated NECPs. 

The Fit for Future Platform underlined the need to ensure consistency of the Governance 
Regulation in view of lessons learnt from the first iteration of NECPs and LTSs 394.  

While  the  survey  results  and  interviews  indicated  that  the  Governance  Regulation  is 
coherent overall and improved coherence in EU and national energy and climate policy, the 
interviews highlighted some major internal coherence issues, primarily between the NECPs 
and  the  national  LTSs  and  the  internal  timeline  of  the  Governance  Regulation.  Table  18 
summarises the coherence issues between the NECPs and LTSs. 

Table 18.  Coherence issues between NECPs and LTSs 

Coherence issue Explanations/evidence 

(Mis)alignment 
between  NECPs 
(mid-term 
and 
planning) 
LTSs  (long-term 
planning) 

The Governance Regulation requires coherence between Member States’ NECPs 
and LTSs but does not provide a clear process or guidelines for this integration395. 

While the intermediate update (after five years) is mandatory for NECPs, it is not 
for LTSs (only ‘where necessary’), which may create misalignments396. Although 

394 Final opinion 2022_SBGR1_03 Governance of Energy and Climate_fup.pdf (europa.eu)  
395 Interviews with third sector organisations (2). Opinion of the Fit for Future Platform. 
396 Interviews with third sector organisations (3). 

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Coherence issue Explanations/evidence 

manifestly outdated397, the LTSs are not in the process of being reviewed398 (while 
final  NECP  updates  are  due  by  30  June  2024).  Consequently,  the  longer-term 
direction remains unclear and misaligned with the shorter-term action. 

Stakeholders pointed to similar inconsistencies in the timeline. 

in 

Differences 
stringency/requ
irements 
importance  

and 

Four stakeholders mentioned that, compared to the NECPs, LTSs have not been 
given sufficient attention399. This was also highlighted for effectiveness (see EQ1). 

The  NECP  template  is  mandatory  (‘shall’),  while  the  LTS  template  is  only 
recommended (‘should’)400. In practice, Annex IV of the Governance Regulation 
(template  for  LTS)  was  fully  followed  by  only  five  Member  States,  and  partly 
followed by a further 12 (see EQ1). 

The  NECP  process  includes  an  iteration  with  the  Commission  for  each  cycle  of 
update: Member States submit first a draft, assessed by the Commission, which 
makes  recommendations,  then  Member  States  submit  a  final  version.  Such  an 
iterative process has not been formally introduced for the LTSs. 

Three stakeholders highlighted a need to more closely assess and monitor LTSs401.   

Table  19  presents  the  coherence  issues  in  relation  to  the  internal  timeline  of  the 
Governance Regulation. 

Table 19.  Coherence issues related to the internal timeline of the Governance Regulation 

Coherence issue Explanations/evidence 

Between  NECP 
and LTS 

Member  States  first  submit  their  NECP  and  then  their  LTS.  Some  stakeholders 
believe  it  would  be  better  to  submit  both  at  the  same  time,  or  submit  the  LTS 
first, to avoid a situation where the longer-term planning depends on the shorter-
term  planning,  with  the  shorter-term  planning  then  becoming  inconsistent  with 
the objectives of the longer-term planning402. 

Between  NECP 
and NECPR 

The sequence between NECPR and NECP may create inconsistencies. For instance, 
one  stakeholder  underlined  that,  in  2023,  the  deadline  for  the  NECPR  was  15 
March, while the deadline for the draft NECP update was 30 June. However, the 

397  Some of the LTSs were prepared before COVID (e.g. PT: June 2019; NL: December 2019; FR: March 2020). 
Some of the LTSs are even older, as they correspond to national strategies adopted before the LTS was required 
as an EU reporting obligation (e.g. DE: November 2016). Overall, most LTS were prepared before the start of 
Russia’s war of aggression against Ukraine and the related energy crisis, and before the pieces of the Fit for 55 
package were adopted. Ecologic’s assessment for the European Climate Foundation in 2022 concluded that some 
LTSs were already outdated (Velten, E.K., Evans, N., Spasova, D., Duwe, M., de la Vega, R., Duin, L. and Branner, 
H.,  Charting  a  path  to  net  zero: An  assessment of  national  long-term strategies  in  the EU,  Ecologic  Institute, 
Berlin, 2022, https://www.ecologic.eu/18646). 
398 Article 15 Governance Regulation requires Member States to prepare their next LTSs by 1 January 2029 (with 
a 30-year perspective, i.e. until 2060). The provision on an update every five years is a ‘should, where necessary’. 
399 Replies to CfE: NGOs (2): CAN Europe; Transport and Environment. Academic/Research institute (1): Ecologic 
Institute. Environmental organisation (1): WWF European Policy Office.  
400 Interview with third sector organisation (1) and opinion of the Fit for Future Platform. ‘Adding a mandatory 
template asking for more detail on the long-term vision (scenarios and targets) and on preparation and use of 
the  document’  is  the first recommendation  on  improving  the  EU  framework  for  LTSs  (Velten,  E.K.,  Evans,  N., 
Spasova, D., Duwe, M., de la Vega, R., Duin, L. and Branner, H., Charting a path to net zero: An assessment of 
national long-term strategies in the EU, Ecologic Institute, Berlin, 2022). 
401 Scoping interview with EU institution (1); Replies to CfE: NGO (2): CAN Europe, Transport and Environment.  
402 Interviews with third sector organisations (2) and opinion of the Fit for Future Platform. 

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Coherence issue Explanations/evidence 

NECPR  should  comment  on  the  NECP,  which  was  still  being  updated  at  that 
time403. Another404 pointed out that the timeframe would not allow for the lessons 
of the NECPRs to be incorporated into the NECP review process. 

Timeline 
assessments 

for 

In practice, the Commission may receive data very late from Member States (see 
EQ1). This results in Commission assessments being completed very rapidly. This 
occurred  in  2023  in  relation  to  the  assessment  of  consistency  of  EU  measures 
towards climate objectives (as  required by the European Climate Law)405. More 
time  is  needed  between  receiving  plans  and  reports  and  completing  the 
assessment. 

Similarly,  there  was  late  submission  of  draft  NECPs  in  2019  and  draft  NECP 
updates in 2023. The deadline for draft NECP updates was 30 June 2023. By the 
end  of  September,  only  15  (of  27)  draft  NECP  updates  were  available.  By 
December 2023, four were still missing, although the Commission’s deadline for 
sending its recommendations to the Member States was 31 December. 

Other timeline challenges were raised in relation to external coherence (see EQ11). 

On possible overlaps or duplication, some inconsistencies were identified (primarily from 
the survey):  

Three national authorities406 pointed to possible overlaps about PaMs, projections and GHG 
inventories  between  NECPs  and  reporting  obligations  under  Articles  17  and  18  of  the 
Regulatioin (NECPRs) and Article 26 (annual reports)407; 

Possible duplication of data collection or reporting with Eurostat (ESTAT) processes: some 
data  may  already  be  collected  by  ESTAT  and  may  be  required  again  for  the  biannual 
reporting (NECPRs)408. In practice, the reporting for NECPRs in Reportnet already includes 
data from ESTAT.  

As the same information might be needed for multiple reporting purposes, the Governance 
Regulation could help to reduce duplication of reporting effort by creating a single reporting 
process for multiple purposes409.  

Several possible contradictions were mentioned by one stakeholder410: 

Article  44  of  the  Governance  Regulation  established  two  committees  (Climate  Change 
Committee  and  the  Energy  Union  Committee)  which  may  contradict  the  objective  of 
integration  and  breaking  silos.  Information  is  shared  between  the  Committees,  and  the 
working groups on NECPs and NECPRs are set up jointly; 

403 Interview with EU institution (1). 
404 Survey of national authorities (1): ES.  
405 Interview with an EU institution (1). 
406 Survey of national authorities (3): LT, PL, SE.  
407 Survey of national authorities (1): PL, ‘Provisions included in Art. 17.3 do not solve the problem but in contrary 
introduce confusion, especially in the context of the fact that the report under Art. 18a is a separate, stand-alone 
report and in the context of the structure of reporting tables in Reportnet 3.0. PaMs report under Art. 18a is a 
separate report and has its own requirements (Commission Regulation 2020/1208) and acceptance path by the 
government, regardless the work on NECPR under Art.17 (and Commission Regulation 2022/2299). In addition, 
many GHG PaMs covered by the report under Art. 18a are also PaMs concerning RES and energy efficiency which 
go to the NECPR under other dimensions of the Energy Union’. 
408 Scoping interview with EU institution (1). 
409 Scoping interview with EU institution (1). 
410 Both examples from the same interview with EU institution (1). 

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Integration of reporting can result in workload peaks, especially when several processes 
occur in the same year, as in 2023 (NECPRs and draft NECP updates). 2023 was the first 
time NECPRs were to be reported, which increased the workload for national authorities. 

The  small  number  of  overlaps,  duplications  and  contradictions  raised  by  stakeholders 
suggests that the Governance Regulation has a good level of internal coherence. 

In  their  responses  on  internal  coherence,  stakeholders  commented  on  aspects  to  be 
covered in the reporting obligations and the balance within the Governance Regulation (i.e. 
between  the  five  dimensions  of  the  Energy  Union,  and  with  other  policy  areas,  such  as 
adaption). The Governance Regulation aims to streamline the reporting obligations of EU 
energy and climate legislation. Most of these obligations are specified in their related pieces 
of legislation (e.g. RED for reporting obligations on RES). The Governance Regulation and 
related processes can make it easier to identify possible risks of inconsistency. However, 
the ambition and weight given to each policy area depends more on the political decisions 
when adopting the corresponding piece of sectoral legislation, than on monitoring in the 
processes  of the  Governance Regulation. Consequently,  some of the  comments in Table 
20 apply to related pieces of legislation rather than to the Regulation itself. 

Table 20.  Coherence  issues  in  relation  to  coverage  and  balance  within  the  Governance 

Regulation 

Policy area 

Coherence issues and comments from stakeholders 

Adaptation 

Evidence from the interviews indicates that adaptation, need for resilience, and 
effects of climate change on energy production were not covered well in the first 
(2019) NECPs. This might be because the template mentions adaptation only as 
a sub-section in the parts on decarbonisation411. Similarly, resilience is mentioned 
in the part on  security of supply. However, the link between resilience of energy 
systems and adaptation may not be made systematically. These issues were also 
highlighted in the Commission’s recommendations to Member States. 

There is no clear requirement for 10-year planning for adaptation.  

The climate dimension of the Governance Regulation might be less covered/given 
less  attention  than  the  energy  dimension.  In  addition  to  adaptation,  another 
example is non-energy sectors relevant for climate-relevant aspects, in particular 
agriculture412.  One  third  sector  organisation  raised  the  same  issue  about 
biodiversity413.  The  Commission’s  assessment  of  the  draft  NECP  updates  shows 
improvements on these issues and circular economy integration. 

Heating 
cooling 

and 

One  EU  institution  underlined  the  gap  in  reporting  on  heating  and  cooling 
assessment. The comprehensive assessments required by the previous EED were 
due  every  five  years  from  2015.  The  next  ones  would  thus  have  been  due  by 
2025.  However,  the  new  EED  aligns  this  reporting  with  the  NECP.  Commission 
guidance  in  December  2022  clarified  that  Member  States  should  include  their 
updated  comprehensive  assessment  with  their  final  NECP  update  due  by  June 
2024.  Meanwhile, gaps in cooling data and about waste heat were identified in 
the draft NECP updates414. 

411 Scoping interview with EU institution (1). 
412 Scoping interview with EU institution (1) and third sector organisations (2). 
413 Interview with third sector organisation (1). 
414 Interview with EU institution (1). 

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Policy area 

Coherence issues and comments from stakeholders 

Financing 

A  third  sector  organisation  stressed  the  importance  for  the  NECPs  to  provide 
information  on  the  financial  means  to  achieve  the  targets415.  This  was  also 
stressed under effectiveness (see EQ1). 

Just Transition  One NCA stated that there should be room for more provisions reporting on the 

Just Transition416. 

First assessments of draft NECP updates seem to indicate improvements between the first 
NECPs (2019) and the draft NECP updates (2023): in the first NECPs, health aspects (air 
quality) were covered to some extent, but energy poverty, employability skills or the Just 
Transition, as well as related policies (e.g. water quantity issues under adaptation) were 
poorly  addressed.  The  new  guidance  for  the  draft  NECP  updates  has  improved  this. 
However, some social aspects remain less well covered, such as growing social concerns 
about landscape related to the impact of renewables417. 

In respect of the practical details (templates and guidelines), stakeholders mentioned some 
other inconsistencies or suggestions for improvements (see Table 21) 

Table 21.  Coherence issues in relation to templates and guidelines 

Template 
guidelines 

or 

Coherence issue(s) or suggestion(s) for improvement 

LTS template 

The  LTS  template  is  recommended  (‘should’)  but  not  mandatory,  whereas  the 
other templates (NECP and NECPR) are mandatory. 

Showing pathways with intermediary targets towards 2050 would make it easier 
to assess consistency between NECPs and LTSs418. 

NECP template  The NECP template includes different chapters for each dimension of the Energy 
Union. Adding a horizontal chapter would help further integration (e.g. how energy 
efficiency  targets  can  have  an  impact  on  renewable  and  energy  security)419. 
Article 3(3)(b) of the Governance Regulation states that the Member States shall 
‘take  into  account  the  interlinkages  between  the  five  dimensions  of  the  Energy 
Union, in particular the Energy Efficiency First principle’. However, this principle is 
mentioned only in footnotes to the NECP template to remind Member States that 
‘Policies and measures shall reflect the energy efficiency first principle’ in sections 
3.3. (energy security) and 3.4 (internal energy market). 

One national authority420 suggested that the NECP template could be simplified, 
pointing to overlaps in the elements included in sections 2, 3, 4 and 5 under each 
dimension. 

NECPR template The template lacks a reference to the EEF principle (Implementing Regulation (EU) 
2022/2299), which is intended to be an overarching principle of the Governance 
Regulation. 

415 Interview with third sector organisation (1). 
416 Scoping interview with NCA (1): CZ. 
417 Interview with EU institution (1). 
418 Interview with third sector organisation (1). 
419 Interview with third sector organisation (1). 
420 Survey of national authorities (1): MT. 

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Template 
guidelines 

or 

Coherence issue(s) or suggestion(s) for improvement 

Guidelines about 
statistics 
and 
data collection 

One  survey  respondent421  noted  that  buildings  and  energy  statistics  are  poorly 
aligned (e.g. renewable energies in buildings), suggesting a need to improve links 
to official (ESTAT) statistics. 

Issues 
definitions 

with 

A  third  sector  organisation  pointed  to  the  lack  of  a  definition  of  ‘fossil  fuel 
subsidies’ and ‘energy poverty’ (the latter is addressed in the new EED), as both 
items are covered by reporting obligations422. 

Analysing the coherence of the Governance Regulation in relation to EU and national energy 
and  climate  policy 
together  various 
planning/monitoring/reporting  obligations,  then  at  the  new  aspects  or  requirements  it 
introduced to promote a more integrated approach. 

it  has  brought 

looks  at  how 

first 

Reporting  on  energy  poverty  is  one  area  where  the  Governance  Regulation  has  made  a 
difference  and  improved  coherence  significantly  within  EU  legislation.  Various  pieces  of 
legislation related to distinct Energy Union dimensions have provisions on energy poverty 
(e.g.  Directive  on  internal  market  for  electricity,  EED,  RED).  The  NECP  and  NECPR 
templates  include  dedicated  sections  (NECP)  or  annexes  (NECPR)  on  energy  poverty, 
where Member States must summarise the main information from policies or frameworks 
related to  energy markets,  energy  efficiency or RES. The previous provisions  on  energy 
poverty  (e.g.  in  the  Electricity  Directive  or  the  EED)  clearly  raised  the  issue  of  energy 
poverty  but  did  not  define  it423,  leaving  Member  States  to  decide  whether  to  apply  the 
corresponding planning, monitoring and reporting requirements. This became more visible 
when  Member  States  had  to  submit  their  first  NECPs  in  2019:  their  submissions  in  the 
sections  dedicated  to  energy  poverty  greatly  varied  in  quality  and  comprehensiveness, 
notably quantitative information on households affected by energy poverty and the details 
of policy action. Seven Member States simply mentioned that the issue was not significant 
or relevant to their national context424. This shows how Member States choices in respect 
of the implementation of the Governance Regulation can reduce its internal coherence.  

A third sector organisation425 gave the example of the EEF principle. In theory, this principle 
should be overarching ‘to take into account the interlinkages between the five dimensions 
of  the  Energy  Union’  (Article  3(3)(b)  Governance  Regulation).  In  practice,  the 
Commission’s assessment of the 2019 NECPs showed that Member States did not integrate 
this  principle.  An  example  of  an  interlinkage  is  energy  security,  where  Member  States 
should not solely focus on measures such as expanding gas storage and constructing new 
pipelines, but, rather, also assess whether strategies to reduce energy consumption could 
enhance energy security. 

The EEF principle was first introduced and defined in EU legislation with the Governance 
Regulation (i.e. it was  not transferred  from separate  reporting obligations). As  stated in 
Article 3(3)(b), it was intended to better integrate the different dimensions of the Energy 
Union. However, at the time of preparing the first NECPs in 2019, no guidance was available 
to the Member States on how to take this principle into account. A recommendation and 
guidelines on the EEF principle were published by the European Commission in September 

421 Survey of national authorities (1): DE. 
422 Scoping interview with third sector organisation (1). 
423 An official definition of energy poverty is now included in the EED (Article 2(52)). 
424 DE, DK, EE, FI, MT, NL, SE. Bouzarovski, S., Thomson, H., Cornelis, M., Varo, A. and Guyet, R., Towards an 
inclusive energy transition in the European Union: Confronting energy poverty amidst a global crisis, Report of 
the  EU  Energy  Poverty  Observatory,  2020,  https://op.europa.eu/en/publication-detail/-/publication/4a440cf0-
b5f5-11ea-bb7a-01aa75ed71a1  
425 Interview with third sector organisation (1). 

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2021426. The Commission’s assessment of the draft NECP updates identified examples of 
where  the  EEF  principle  was  reflected  (e.g.  draft  NECP  updates  of  Cyprus,  Greece, 
Lithuania, Luxembourg, Romania, Spain). It concluded, however, that ‘it is important that 
the final updated NECPs are more explicit in detailing how Member States will implement 
this principle’. The further improvements needed should be supported by Article 3 of the 
new EED, which sets a clearer legal basis for the implementation of the EEF principle427. 

5.1.3.1  EQ11  – To  what  extent  is  the  Regulation  coherent  with  other  EU  and 

international obligations (external coherence)? 

The Commission’s proposal for the Governance Regulation was prepared in parallel with its 
reviews of the EED, the EPBD, the RED, and the various pieces of legislation encompassed 
by  the  Market  Design  Initiative,  with  a  view  to  ensuring  full  coherence  between  these 
initiatives428,  including  the  Electricity  Market  Design  (EMD)429  reform  and  the  Gas 
package 430. These revisions or new pieces of legislation included changes or new reporting 
obligations linked to the processes of the Governance Regulation431.  

The Governance Regulation streamlined the provisions of the MMR with legislation in the 
energy  field,  updated  the  previous  provisions  to  make  them  fit  for  monitoring  the 
implementation of the ESR and LULUCF Regulation and for fulfilling the EU's commitments 
under  the UNFCCC  and  the  Paris  Agreement.  As  the  proposal  covers  a  range  of  subject 
areas, it was decided not to propose a recast of the MMR432.  

Although  the  Governance  Regulation  streamlined  previous  scattered  planning  and 
reporting  obligations,  issues  that  affect  the  external  coherence  of  the  Governance 
Regulation  with  other  EU  and  international  obligations  were  identified 433.  The  legislative 

426 European Commission, ‘Commission publishes recommendation and guidelines on the energy efficiency first 
principle’,  Press  release,  28  September  2021,  https://commission.europa.eu/news/commission-publishes-
recommendation-and-guidelines-energy-efficiency-first-principle-2021-09-28_en  
427 See, for example, discussions at the webinar ‘Integrating Energy Efficiency First in the final update of National 
Energy and Climate Plans’, https://ieecp.org/2024/03/04/integrating-energy-efficiency-first-in-the-final-update-
of-national-energy-and-climate-plans-enefirst-plus-webinar-materials/   
428  Proposal for  a  Regulation  of the  European  Parliament  and  of  the  Council  on  the  Governance  of  the  Energy 
Union, amending Directive 94/22/EC, Directive 98/70/EC, Directive 2009/31/EC, Regulation (EC) No 663/2009, 
Regulation (EC)  No  715/2009,  Directive  2009/73/EC,  Council Directive  2009/119/EC,  Directive  2010/31/EU, 
Directive 2012/27/EU, Directive 2013/30/EU and Council Directive (EU) 2015/652 and repealing Regulation (EU) 
No 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM:2016:759:REV1  

COM/2016/0759 

2016/0375, 

525/2013, 

final/2 

- 

for 

and 

gases 

natural 

(recast), 

hydrogen 

429 Proposal for a Regulation of the European Parliament and of the Council amending Regulations (EU) 2019/943 
and (EU) 2019/942 as well as Directives (EU) 2018/2001 and (EU) 2019/944 to improve the Union’s electricity 
market design, 2023/0077(COD), https://data.consilium.europa.eu/doc/document/ST-16964-2023-INIT/en/pdf  
430 Proposal for a Regulation of the European Parliament and of the Council on the internal markets for renewable 
2021/0424(COD), 
and 
https://data.consilium.europa.eu/doc/document/ST-16522-2023-INIT/en/pdf;  Proposal  for  a  Directive  of  the 
European Parliament and of the Council on common rules for the internal markets in renewable and natural gases 
and  in  hydrogen  (recast),  2021/0425(COD),  https://data.consilium.europa.eu/doc/document/ST-16516-2023-
INIT/en/pdf   
431 For example, Article 19d EMD requires that the indicative national objective on flexibility, as well as measures 
to achieve this objective, shall also be reflected in Member States’ NECPs. Another example in the Gas package 
comes  from  Article  51  of  the  Directive,  that  requires  that  the  network  development  plan  for  natural  gas  and 
hydrogen to be in line with the NECP and its updates. 
432  Proposal for  a  Regulation  of the  European  Parliament  and  of  the  Council  on  the  Governance  of  the  Energy 
Union, amending Directive 94/22/EC, Directive 98/70/EC, Directive 2009/31/EC, Regulation (EC) No 663/2009, 
Regulation (EC)  No  715/2009,  Directive  2009/73/EC,  Council Directive  2009/119/EC,  Directive  2010/31/EU, 
Directive 2012/27/EU, Directive 2013/30/EU and Council Directive (EU) 2015/652 and repealing Regulation (EU) 
No 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM:2016:759:REV1  
433 For example, due to changes in the flexibility mechanism between the LULUCF Regulation, ESR and ETS, where 
there are issues with the accounting and reporting of these flexibilities on an annual basis, and the comprehensive 
review will be in 2025 and 2027. 

COM/2016/0759 

2016/0375, 

525/2013, 

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Energy Union and Climate Action 

changes  introduced  after  2018  significantly  impacted  the  external  coherence  of  the 
Governance Regulation.  

The  evaluation  discusses  how  the  external  coherence  of  the  Governance  Regulation  is 
perceived by stakeholders overall, and how the Regulation provides an umbrella framework 
for  external  coherence.  The  main  coherence  issues  identified  are  then  summarised, 
including  the  challenge  of  maintaining  coherence  over  time,  timing  and  misalignments, 
multi-level coherence, and the complexity of ensuring coherence with the overall EU policy 
framework.  This  is  complemented  with  summary  tables  on  coherence  issues  specific  to 
interactions  with  other  parts  of  the  EU  policy  framework  or  other  relevant  international 
frameworks: the Fit for 55 package, the European Climate Law, EU environmental laws, 
the Paris Agreement (and UNFCCC), and other laws or frameworks. 

Similar  to  internal  coherence,  national  authorities  generally  had  a  positive  view  of  the 
external  coherence  of  the  Governance  Regulation  with  major  EU  laws  and  international 
agreements  (see  Figure  40).  Respondents  were  more  certain  of  the  coherence  between 
the Governance Regulation and other legislation or agreements with direct interactions on 
planning,  monitoring  and  reporting  (Fit  for  55  package,  European  Climate  Law, 
UNFCCC/Paris Agreement) than for other EU initiatives and the Aarhus Convention. Nearly 
half (11 of 23) of the national authorities that responded did not know whether or not the 
Governance Regulation is coherent with the Aarhus Convention.  

Figure 40. Respondents’  views  on  the  Governance  Regulation’s  external  coherence 

(national authorities) 

Source: ICF, based on survey of national authorities. 

Third sector organisations had a positive view of the external coherence of the Governance 
Regulation, albeit to a lesser  extent than national authorities (see Figure 41).  However, 
five of the seven third sector respondents did not believe that the Governance Regulation 
is coherent with the Aarhus Convention. These results should be read with caution as the 
number  of  answers  is  limited.  Nevertheless,  the  answers  on  the  Aarhus  Convention  are 
consistent with the analysis of multi-level and multi-stakeholder dialogue and consultation 
(see EQ6). 

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Energy Union and Climate Action 

Figure 41. Respondents’ views on the Governance Regulation’s external coherence (third 

sector organisations) 

Source: ICF, based on survey of third sector organisations. 

5.1.4  Coherence issues with the Aarhus Convention 

The EU and its 27 Member States are Parties to the Aarhus Convention. Under Article 7 
of that Convention, they must fulfil certain standards in relation to public participation 
procedures ‘concerning plans, programmes and policies relating to the environment’.  

Recital 28 of the Governance Regulation recalls that Member States should involve the 
public  in  the  preparation  of  NECPs  ‘where  applicable’,  in  accordance  with  the  Aarhus 
Convention.  Recital  29  also  refers  to  the  Convention,  implying  its  applicability  to  the 
public consultation procedures required by Article 10 of the Regulation.  

The UNECE’s Aarhus implementation guidelines note that ‘Article 7 applies to all plans 
and programmes regarding the environment. It does not expressly exclude modifications 
[…] from its scope’. . In line with the Convention, the Governance Regulation recalls that 
the  procedure  of  Article  10  on  public  consultation  shall  apply  the  preparation  and 
assessment of the updated NECP. Along these lines, the Commission reminded Member 
States  to  ensure  ‘early  and  inclusive  public  participation  in  line  with  the  Aarhus 
Convention’ in its 2022 guidance on the NECP updates434. Most significantly, the UNECE’s 
Aarhus  Convention  Compliance  Committee  (ACCC)  recognised  the  Convention’s 
applicability  to  both  NECPs  and  their  updates  in  its  2023  decision  A  Sud  Ecologia  e 
Cooperazione Odv ETS v Italy435. 

With regard to national LTS, the ACCC has not yet had to rule on the applicability of the 
Convention, but in the course of the consultation stakeholders indicated that given the 

434 Commission Notice on the Guidance to Member States for the update of the 2021-2030 national energy and 
climate 
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52022XC1229(02)    
435 
https://unece.org/sites/default/files/2023-08/Comunication_ASEC_05.08.2023_redacted.pdf 

Committee, 

Compliance 

Convention 

Decision 

495/02, 

2022/C 

Aarhus 

August 

plans, 

2023, 

of 

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Energy Union and Climate Action 

importance of the LTSs and the broad scope of Article 7 of the Aarhus Convention, as 
outlined in the UNECE implementation guidelines436.  

On concrete plans and strategies adopted by the Member States under their obligations 
stemming from the Governance Regulation, the responsibility to comply with the Aarhus 
Convention arguably lies with the Member States rather than with the EU itself, as clearly 
stated  by  the  relevant  articles  and  recitals  of  the  Governance  Regulation.  However, 
Article  7  also  requires  the  Parties  to  the  Convention  (including  the  EU)  to  establish  a 
‘transparent and fair framework’ for public participation. With this in mind, third sector 
advocates have argued that the Governance Regulation’s framework is itself insufficient. 
The  ACC  also  invited  the  European  union  to  provided  evidence  that  it  has  adopted  a 
regulatory  framework  and/or  clear  instructions  for  implementing  article  7  of  the 
Convention with respect to the adoption of National Energy and Climate Plans 437.  

The seventh Meeting of Parties to the Convention, in October 2021, was satisfied that 
the EU had put in place ‘a regulatory framework that meets the requirements of Article 
6(3)  of  the  Convention  [i.e.  providing  for  reasonable  consultation  timeframes]  with 
respect  to  [NECPs],  but  criticised  that  the  EU  has  not  yet  demonstrated  that  it  has 
adopted either a proper regulatory framework  or clear instructions to  ensure that the 
other requirements of Article 7 are met’ 438.  

The Meeting of the Parties urged the EU to provide evidence of its legislative, regulatory 
or practical measures to ensure that in adopting the NECPs, Member States would meet 
the  Aarhus  Convention’s  standards  for  transparency,  fairness  and  timeliness  of  public 
participation. It further asked the Commission to ‘adapt the manner in which it evaluates 
[NECPs] accordingly’439. 

The  Commission  submitted  an  action  plan 440  to  the  ACCC  in  July  2022.  The  plan 
contained  concrete  measures  to  implement  the  ACCC's  recommendations,  such  as 
providing assistance to Member States or assessing progress on public participation in 
preparing the draft updated NECPs. 

In line with its Action Plan, the Commission included, in its guidance of December 2022 
for  the  Member  States’  NECP  updates,441    a  section  on  ‘Early  and  inclusive  public 
participation in line with the Aarhus Convention’, reiterating Member States’ obligations 
regarding  public  participation  under  both  the  Governance  Regulation  and  the  Aarhus 
Convention.  The  Commission  announced  that  it  would  conduct  a  more  detailed 
assessment of Member States’ compliance with Article 10 of the Regulation442. 

in 

the 

EEB, 

rights 

2023, 

Regulation, 

Governance 

436 Robert, J., The EU’s climate and energy framework in light of the Aarhus Convention - Assessing environmental 
democracy 
https://eeb.org/wp-
content/uploads/2023/12/20231026-Aarhus-Convention-and-Governance-Regulation_0.pdf;  Stockhaus,  H., 
Stakeholder exclusion likely? Public Participation under the Governance Regulation, An Assessment of Article 10 
in the light of the Aarhus Convention, Ecologic Institute, 2018, https://www.ecologic.eu/15615  
437 Aarhus Compliance Committee, Decisio n VII/8f concerning the compliance by the European Union under the 
Convention of 18-20 October 2021 
438 Decision VII/8f of the Meeting of the Parties on compliance by the European Union with its obligations under 
the Convention adopted by the Meeting of the Parties at its 7th session, https://unece.org/env/pp/cc/decision-
vii8f-concerning-european-union 
439 Ibid. 
440 
at 
https://circabc.europa.eu/ui/group/3b48eff1-b955-423f-9086-0d85ad1c5879/library/c6f69753-45bc-4fca-961c-
71d0dddf3c0d/details?download=true. 
441 Commission Notice on the Guidance to Member States for the update of the 2021-2030 national 
energy and climate plans (2022/C 495/02). 
442 European Commission, Progress report on the implementation of the recommendations in 
paragraphs 2(a)-(b), 8(a)-(b) and 10 of decision VII/8f as adopted by the 
Meeting of the Parties to the Aarhus Convention (MoP), 2023. 

European 

available 

decision 

(2022), 

VII/8f, 

action 

Union 

Plan 

for 

of 

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Energy Union and Climate Action 

On 7 June 2024, the ACCC has welcomed the level of engagement and progress made 
in that direction by the European Union, but considers that it has not yet demonstrated 
that the requirements of its decision are fulfilled. 

During  the  consultation  activities  conducted  for  the  evaluation,  some  stakeholders’ 
criticism persists in relation to:  

•  The Commission’s acceptance of Member States’ consultation proceedings, whose 
finalisation, critics point out443, is too late to enable ‘effective public participation’ 
at a time when ‘all options are open’ (as per Article 6(4) Aarhus Convention). 

•  Absence of an explicit reiteration of the Aarhus Convention’s requirements under 

Article 7 in the text of the Governance Regulation.444 

The open questions from the survey and interviews provided more detailed information. 

Interview feedback highlighted that without the Governance Regulation there would be no 
comparable  overview  of  information,  making  it  more  difficult  to  meet  international 
obligations, especially under the Paris Agreement. Several stakeholders pointed out that 
the  annual  State  of  the  Energy  Union’s  progress  report  (due  by  the  end  of  October)  is 
available  before  each  year’s  COP,  which  matches  with  international  obligations  and 
meetings445. On complementarity with international reporting, one NCA stressed that data 
used for NECPs can also be used for reporting to the International Energy Agency (IEA) 446. 
This  also  implies  that  consistency  between  the  Governance  Regulation  timeline  and 
international reporting timelines should be reviewed regularly. 

The Governance Regulation was acknowledged by three third sector organisations as the 
single tool that gathers together many plans, necessitating investment to implement these 
plans447. It sets an overall timeline, with regular deadlines that remain unchanged, even 
in times of broad context changes (e.g. European Green Deal, COVID-19 outbreak, Russia’s 
war of aggression against Ukraine and the resulting energy crisis). This provides a ground 
for clarity and predictability for recipients and investor by maintaining the general process 
for  planning/monitoring/reporting,  while  keeping  the  flexibility  to  revise  legislation.  The 
timeline provides both: 

A feedback loop, through the NECPRs every two years, with information on progress and 
possible gaps in implementation and achievements; 

The possibility to update and refine planning (including targets, scenarios and sets of PaMs) 
every five years, with the NECPs and NECP updates. This is not ensured for longer term 
planning, however, as there is no mandatory intermediate update of the LTSs (see EQ10). 

443  Swords,  P.,  Comments  on  first  progress  report,  UNECE,  2023,  https://unece.org/sites/default/files/2023-
11/frCommVII.8f_C54_C96_29.10.2023.pdf.  
444  EEB,  CAN  Europe  and  others,  A  revised  and  responsive  Governance  Regulation  Respecting  environmental 
democracy rights in climate planning. Joint NGO position paper on the revision of Regulation 2018/1999 on the 
Governance  of  the  Energy  Union  and  Climate  Action,  2024,  https://unece.org/sites/default/files/2024-
04/frObsVII.8f_CAN_others_29.03.2024_position_paper.pdf 
445 Interviews with EU institutions (2) and NCA (1). 
446 Interview with NCA (1). 
447 Interviews with third sector organisations (3). However, how Member States report investment and financing 
needs varies significantly, especially in their comprehensiveness and clarity. 

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One stakeholder stressed that this was illustrated in the case of SET plans448: even if SET 
plans  change,  the  Governance  Regulation  remains  valid  in  relation  to  reporting  on 
technologies, because it is sufficiently flexible rather than prescriptive449. 

The  timeline  that  includes  the  NECP  process  is  iterative  and  supports  a  learning  curve, 
particularly for the NECP (with a draft commented on by the Commission before submission 
of final version by the Member States). Member States receive an external view of their 
plans and can benchmark against other Member States’ reports. 

The Governance Regulation is considered when introducing or revising EU laws. This was 
the case, for example, when introducing the European Climate Law, which contributes to 
external  coherence  for  the  Governance  Regulation  through  its  requirement  for  the 
Commission to regularly assess consistency of EU measures towards climate objectives 450.  

Overall,  stakeholders  highlighted  several  coherence  issues,  chiefly  the  challenge  of 
maintaining coherence over time: 

Related pieces of legislation may change faster than the Governance Regulation, creating 
inconsistencies  or  misalignment,  e.g.  the  new  legislative  framework  with  the  European 
Climate Law, the Biodiversity Strategy, the Circular Economy Action Plans, or the Fit for 
55 package; 

Inconsistencies  in  the  timeline  may  be  addressed  by  updated  legislative  instruments, 
creating  a  conflict  between  (1)  keeping  the  initial  deadlines  (e.g.  for  NECP  updates)  to 
maintain  predictability  and  alignment  with  the  general  framework,  and  (2)  considering 
adjusting  deadlines  where  this  may  increase  the  relevance  of  the  plans  submitted 
(reflecting EU laws recently or about to be adopted or revised); 

The need for future updates, such as the new article proposed by the  NZIA451 requiring 
NECPs  to  describe  how  Member  States  will  contribute  to  the  objectives  of  the  Act.  This 
might come too late for the current round of NECP updates by June 2024, meaning it would 
not be reflected in the NECPs until 2028452.  

According  to  one  consulted  stakeholder,  a  key  point  to  clarify  and  communicate  is  that 
target-setting  at  EU  level  is  a  separate  process  from  the  Governance  Regulation,  as  it 
follows the political, rather than reporting, cycle453. Stakeholders' responses suggest that 
this issue remains unclear to many. 

Stakeholders raised other timing and (mis)alignment issues. For example, the timelines of 
different planning processes (e.g. NECPs, REPowerEU chapters, Social Climate Plans) are 
not aligned 454. They also mentioned that energy data must be delivered at a certain time 455 

Article 

Parliament, 

448 European Commission, Strategic Energy Technology Plan, n.d., https://energy.ec.europa.eu/topics/research-
and-technology/strategic-energy-technology-plan_en  
449 Interview with European institution (1). 
450 Interview with EU institution (1). 
451 Articulation with National Energy and Climate Plans) in the provisional agreement between the Council and 
the 
https://www.consilium.europa.eu/en/press/press-
2024, 
releases/2024/02/06/net-zero-industry-act-council-and-parliament-strike-a-deal-to-boost-eu-s-green-industry/  
452 Interview with a third sector organisation (1). 
453 Interview with European institution (1). 
454 Reply to CfE: NGO (1). Scoping interview with EU institution. 
455 Annex B (point c) requires that Member States submit their data for annual energy statistics by 31 October of 
the  year  following  the  reported  year  (Commission  Regulation  (EU)  2022/132  of  28 January  2022  amending 
Regulation (EC) No 1099/2008 of the European Parliament and of the Council on energy statistics, as regards the 
implementation  of  updates  for  the  annual,  monthly  and  short-term  monthly  energy  statistics,  C/2022/380, 
http://data.europa.eu/eli/reg/2022/132/oj  

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for  ESTAT,  but  this  runs  partly  in  parallel  with  preparing  the  NECPR,  creating  some 
inefficiencies456.  

Stakeholders  identified  clashes  with  other  national-level  cycles  for  the  adoption  of 
local/national  plans457.  Rather  than  aligning  all  timelines  at  EU,  national  and  local  level, 
there  appears  to  be  a  need  to  ensure  better  coordination  (see  EQ6).  One  example  is 
assessing  the  contribution  of  sub-national  targets  (e.g.  from  Sustainable  Energy  and 
Climate Action Plans (SECAPs)) to achieving national targets. One third sector organisation 
advocated aligning sub-national planning with the NECP458. Another example is the local 
heating  and  cooling  plans  required  by  the  new  EED  (Article  25(6)),  which  could  be 
coordinated with the national comprehensive heating and cooling assessments, then taken 
into  account  in  the  NECP459.  Similarly,  when  national  plans  are  not  coherent  with  EU 
targets,  this  may  create  difficulties  for  stakeholders  needing  to  prepare  scenarios 
considering interactions between countries (e.g. TSOs) 460. 

When  considering  external  coherence  with  the  overall  EU  policy  framework,  the  main 
challenge is how to address complexity. The multitude of different national plans mandated 
by  EU  energy  and  climate  legislation  and  other  relevant  legislation  and  processes  risks 
incoherence  and  missed  opportunities  for  synergies461.  This  not  only  includes  the 
consistency  between  NECPs  and  LTSs,  but  extends  to  a  variety  of  other  national  plans, 
such as Just Transition, Social Climate Fund, RRPs and CSPs462. For example, the 2020 EU-
wide assessment of the final NECPs found that they lacked a clear prioritisation of funding 
needs for the Just Transition and investment needs for reskilling, upskilling and support of 
labour market adjustments. A large majority of Member States still need to develop clearer 
strategies  and  objectives  through  a  cross-cutting  approach  to  identify  and  measure  the 
social, employment and skills consequences and other distributional impacts of the energy 
transition and carefully consider how to address these challenges463. Further issues related 
to the Just Transition were highlighted in the 2023 EU-wide assessment of the draft NECP 
updates464.  It  called  for  further  measures  to  address  agricultural  emissions  and  for  the 
quantification  of  their  expected  impacts.  In  finalising  the  NECP  updates,  Member  States 
were  also  recommended  to  ‘better  describe  synergies  with  their  national  common 

456 Interview with NCA (1). 
457 Scoping interviews with EU institution and NCA; Interview with NCA (1). 
458 Interview with third sector organisation (1). 
459 Interview with third sector organisation (1). 
460 Interview with industry organisation (1). 
461 Oberthür, S., Moore, S., von Homeyer, I. and Söebech, O., Towards and EU Climate Governance Framework 
to Deliver on the European Green Deal, Policy paper, 2023; Scoping interviews with EU institutions (2). 
462  European  Commission,  CAP  Strategic  Plans,  n.d.,  https://agriculture.ec.europa.eu/cap-my-country/cap-
strategic-plans_en  
463 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee  and  the Committee  of  the  Regions,  An  EU-wide  assessment  of  National  Energy  and Climate 
Plans:  Driving  forward  the  green  transition  and  promoting  economic  recovery  through  integrated  energy  and 
climate 
https://eur-lex.europa.eu/legal-
564 
content/EN/TXT/PDF/?uri=CELEX:52020DC0564  
464 For example: ‘Some Member States appear to be backtracking on previous commitments in the Territorial Just 
Transition  Plans  approved  by  the  Commission  in  2022.  On  fossil  fuel  subsidies,  a  collective  effort  by  Member 
States is necessary to set a clear and credible timeline for their phase out. To support the Just Transition, Member 
States have only provided a partial assessment of the socioeconomic impacts of the climate and energy transition 
on  individuals,  households  and  companies,  and  the  related  policies  and  measures  often  lack  a  strategic  and 
forward-looking  vision’  (  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the 
European Economic and Social Committee and the Committee of the Regions, 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,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2023%3A796%3AFIN&pk_campaign=preparatory&pk_source=EURLEX&pk_medi
um=TW&pk_keyword=EUGreenDeal&pk_content=Communication&pk_cid=EURLEX_todaysOJ). 

COM(2020) 

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agricultural policy strategic plans (CSPs) and explain the integrated national approach to 
increase the effort’. 

Addressing  complexity  and  interactions  is  done  progressively  by  including  references  in 
other  policy  or  funding  frameworks  explaining  that  national  implementation  should  be 
coherent with the NECPs (e.g. in regulations for REPowerEU465 or the RRF). Mapping the 
interactions  between  the  Governance  Regulation  and  other  plans  may  help  to  identify 
opportunities for streamlining466. 

Specific coherence issues were raised between the Governance Regulation and the different 
parts of the EU policy framework and other relevant international agreements (mainly the 
Paris Agreement and UNFCCC), as summarised in Tables 22, 23.  

Table 22.  Coherence issues arising from changes introduced by the Fit for 55 package 

Coherence issue Explanations/evidence 

Misalignment 
with 
legislation 

new 

The new RED and EED change the gap filler/gap ambition mechanisms 

Member States must now submit a series of new (Social Climate Plans467, local 
heating  and  cooling  plans468,  national  policy  frameworks  for  alternative  fuel 
infrastructure469)  or  revised  plans  (e.g.  national  building  renovation  plans 
replacing previous LTRSs)470  

The new RED introduces new elements (e.g. new indicative target for innovative 
renewable energy technology).  

The new EED includes many new elements for stronger governance that are not 
currently incorporated or streamlined into the Governance Regulation, including 
the  EEF  principle471  and  the  requirement  to  define  a  minimum  share  of  energy 
savings  to  achieved  among  priority  groups.  The  Fit  for  Future  Platform  also 
underlined  the  need  to  modernise  the  energy  efficiency  dimension  of  the 
Governance Regulation in line with the new EED472  

Timeline issues  Despite the guidance published in December 2022473, several draft NECP updates 
do  not  refer  to  the  Fit  for  55  package,  as  the  deadline  to  provide  the  draft 
NECP updates was before the full adoption of key pieces of the package 

Two replies to the CfE underlined that the NECPs (due at the end of 2019) were 
out  of  sync  with  the  EPBD’s  LTRSs  (due  in  March  2020),  which  limited  positive 

465  One  third  sector  organisation  noted  that  REPowerEU  introduced  new  milestones  for  2030,  some  explicit 
(renewable energy, energy efficiency), others implicit (reducing gas use by 2030 compared to 2019). These are 
not binding objectives but were considered in the final negotiations of the Fit for 55 legislation. There might then 
be contradictions in the NECP updates currently prepared by the Member States and what is expected at EU level. 
While the process of the Governance Regulation should allow possible gaps and contradictions to be identified 
(e.g. projections of gas use), it is unclear how these could be resolved when they deal with non-binding objectives. 
Similarly,  from  the  guidelines  of  REPowerEU,  NECPs  are  supposed  to  help  to  implement  REPowerEU,  but 
REPowerEU is not yet integrated in the Governance Regulation and might not be (primarily non-binding). There 
might then be confusion between binding and non-binding targets, and risks of inconsistencies among the Member 
States and with EU level. 
466 Scoping interview with EU institution (1). 
467 Article 4 Regulation (EU) 2023/955. 
468 Article 25(6) EED. 
469  ‘National  policy  framework  for  the development of  the  market  as  regards  alternative  fuels  in  the  transport 
sector and the deployment of the relevant infrastructure (see Article 14 Regulation (EU) 2023/1804). 
470 Scoping interview with NCA (1); Interviews with EU institution (1) and third sector organisation (4). 
471 Replies to CfE: NGOs (2); Business associations (2); Public authority (1); Company/Business (1); Other (1) 
472 Final opinion 2022_SBGR1_03 Governance of Energy and Climate_fup.pdf (europa.eu) 
473 Commission Notice on the Guidance to Member States for the update of the 2021-2030 national energy and 
climate 
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52022XC1229(02)    

495/02, 

2022/C 

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Coherence issue Explanations/evidence 

synergies for national planning of building renovations474. A similar situation 
is  likely  to  occur  for  the  Building  Renovation  Plans  (BRPs),  which  replaced  the 
LTRSs, as per the recast EPBD, which was agreed in December 2023 close to the 
deadline for submitting the final NECP updates. Thus, the first BRPs will have to 
be submitted outside the NECP framework, given the importance and urgency of 
scaling-up  renovation  based  on  solid  plans.  Nevertheless,  the  recast  EPBD 
foresees that the following BRPs will be fully synchronised with the NECP cycle 

Table 23.  Coherence issues with European Climate Law 

Coherence issue Explanations/evidence 

for 
in  the 

Needs 
updates 
Governance 
Regulation 

The European Climate Law was introduced after the Governance Regulation, which 
was then amended to reflect the long-term goal of climate neutrality. A further 
update is needed in view of preparing the 2040 ambition475 

There is no established methodology for the Commission to track progress 
towards climate neutrality or the consistency of measures to achieve climate 
neutrality.  Similarly,  the  Governance  Regulation  could  clarify  the  definition  of 
scope of climate neutrality targets476. The Commission already tracked progress 
towards neutrality in the Climate Action Progress Reports in 2023 and based on 
this,  issued  recommendations  under  the  European  Climate  Law,  which  could 
provide an initial basis 

Timeline issues  The  sequencing  and  timing  of  the  main  governance  processes  under  the 
Governance Regulation (Articles 29 and 35) and the European Climate Law is not 
fully coherent477. These are currently partially out of sync such that information 
(e.g. from assessments under Articles 6 and 7 of the European Climate Law) is 
not  available  in  time  to  inform  planning  processes  under  the  Governance 
Regulation, and vice versa 

Both pieces of legislation have their own process for making recommendations to 
Member States. The assessments required by the European Climate Law to 
be done by the Commission (Articles 6-8) need to be completed by 30 September. 
These  assessments  are  close  to  assessments  done  under  Governance 
Regulation  to  be  reported  by  31  October  (in  the  State  of  the  Energy  Union’s 
progress reports)  

A misalignment may occur for the next cycle: Member States need to submit their 
draft NECPs by 1 January 2028, which will be assessed by the Commission, with 
recommendations due by 1 July 2028. The Commission’s assessment under the 
European Climate Law is to be done by September 2028, just after the assessment 
of draft NECP recommendations 

474 Replies to CfE: NGOs (1); Other (1). 
475 Interview with third sector organisation (1). 
476 Interview with third sector organisation (1). 
477 Reply to CfE: Academic (1) 

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Table 24.  Coherence issues with EU environmental laws, policies, and objectives 

Coherence issue Explanations/evidence 

Insufficient links 
with 
the 
environmental 
priorities  of  the 
European  Green 
Deal  

The  issue  relates  to  biodiversity,  zero  pollution,  water  resilience  and  circular 
economy, among others, particularly how energy and climate policies may affect 
different  areas  of  the  environment.  The  possible  connections,  externalities  and 
synergies of the actions included in the NECPs and LTSs could be better considered 
in  view  of  the  European  Grean  Deal  environmental  priorities,  which  could  also 
improve the application of the DNSH criterion  

political 

processes 

Three  stakeholders478  mentioned  that  biodiversity  is  not  covered  extensively  in 
the Governance Regulation. However, there seems to be confusion about the role 
of  the  Governance  Regulation  in  this  field,  as  some  comments  related  to  RES 
objectives (e.g. increased use of biomass for energy production) that are decided 
in 
Regulation 
(planning/monitoring/reporting). Nevertheless, the new RED includes provisions 
related  to  planning/monitoring/reporting  (e.g.  bioenergy,  biomass  trajectories 
and  link  with  LULUCF),  which  could  present  opportunities  to  explore  coherence 
with biodiversity objectives and environmental policies. For example, Article 3(3d) 
of  the  Governance  Regulation  requires  the  Commission  to  publish,  by  2027,  a 
report  on  the  impact  of  Member  States’  support  schemes  for  biomass  on  the 
climate and the environment 

Governance 

outside 

the 

of 

Another  example  of  the  environmental  impacts  of  RES concerns  the  interaction 
with Directive 92/43/EEC (Habitats Directive)479. There can be conflicts between 
the  nature  conservation  objectives  and  the  objectives  of  accelerating  the 
deployment  of  RES480.  Such  issues  may  not  be  reported  in  the  process  of  the 
Governance  Regulation.  The  new  RED  includes  provisions  in  this  area,  and  the 
Commission looks at aspects such as biodiversity in its assessment of the NECP 
updates 

In other cases, synergies and effectiveness gains can be achieved, e.g. in ensuring 
water resilience against floods and droughts and the climate adaptation strategies 
prepared under the Governance Regulation 

more 

Opportunities 
for 
synergies 
between energy, 
and 
climate, 
environmental 
policies 

This  is  illustrated  in  the  coordination  for  the  preparation  of  the  NECPs  and  the 
National Air Pollution Control Programmes under the NEC Directive481. The 2023 
EU-wide assessment of the draft NECP updates highlighted that integration could 
be  improved  here,  as  well  as  in  the  field  of  circular  economy482.  This  may  also 
reflect timeline issues (see next point) 

478 Interviews with NCA (1), EU institution (1) and third sector organisation (1). 
479 Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and 
flora, http://data.europa.eu/eli/dir/1992/43/2013-07-01  
480 Scoping interviews with third sector organisations (2). 
481 Reply to CfE: Public authority (1). 
482  ‘Exploring  further  the  benefits  of  environmental  policies  can  strengthen  the  final  NECPs,  notably  on-air 
pollution, water, and the circular economy. 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 Directive,  nor on  the  alignment  of  National  Air  Pollution  Control  Programme  (NAPCP) 
with energy and climate programmes. Similarly, most plans would benefit from the integration of the principles 
and  practices  of  water  and  circular  economy  policies,  for  their  potential  to  reduce  GHG  emissions  and  foster 
strategic  autonomy  and  climate  change  adaptation.  The  plans  should  also  consider  other  circular  economy 
practices than waste management, including eco-design and circular business models, to prevent and decrease 
more effectively GHG emissions’. 

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Coherence issue Explanations/evidence 

Timeline issues  There  are  challenges  in  the  coordination  of  timelines  for  the  preparation  of  the 
NECP  and  the  National  Air  Pollution  Control  Programme  under  the  NEC 
Directive483.  The  first  National  Air  Pollution  Control  Programme  was  due  by  1 
April 2019. Member States are required to update them at least every four years, 
with a different pattern to the NECPs (also started in 2019, but with updates every 
five years). Given that the NECPs set out the national energy and climate policy 
framework, the submission deadline for the final NECPs should ensure that they 
are available well in advance of other plans and programmes to be developed in 
coherence with that framework 

Table 25.  Coherence issues with Paris Agreement and UNFCCC 

Coherence issue Explanations/evidence 

Timeline issues  The  most  frequently  cited  issues  related  to  the  misalignment  of  biennial 
reporting  on  GHG  emissions  for  the  Governance  Regulation  (NECPR,  in  odd 
years) and the Paris Agreement (BTR, in even years)484. In practice, Member 
States must report every year, which goes against the streamlining objective. This 
may  also  create  additional  work  to  generate  projections  for  both  frameworks 
(UNFCCC and the EU) that are then less useful as they are not comparable485. The 
reasons for this misalignment could be further explored. It may be because the 
reporting year for the UNFCCC was adjusted after the reporting year for NECPRs 
was proposed 

The multiple reporting deadlines in 2023 (NECPR in March, draft NECP update 
in  June)  and  2024  (final  NECP  update  in  June,  BTR  end  of  2024)  may  create 
confusion  about  what  data  should  be  used  in  the  NECP  (especially  on 
projections of GHG emissions) 

Another  issue  concerns  the  alignment  of  the  five-year  updating  cycles 
between the Governance Regulation and the UNFCCC processes, which should be 
strengthened,  as  foreseen  by  Article  4(7)  of  the  European  Climate  Law486.  The 
update of LTSs every five years is not mandatory487 

Table 26.  Coherence issues with other laws or frameworks 

Law 
framework 

or 

Issue(s) and explanations 

ESR 

Timeline issues:  

Member  States’  progress  towards  meeting  their  national  emission  reduction 
targets  under  the  ESR  is  assessed  annually  (based  on  the  Governance 
Regulation), and if a Member State makes insufficient progress it needs to submit 
a corrective action plan (under the ESR). Whether Member States complied with 
their annual ESR targets for each of the years 2021-2025 will be assessed in 2027, 
and in 2032 for the years 2026-2030. This timeline was decided to streamline and 

483 Reply to CfE: Public authority (1). 
484 Scoping interviews with NCAs (2); Interviews with NCA (1) and EU institution (1). 
485 Scoping interviews with NCA (1) and EU institution (1); Interviews with NCAs (2). 
486 Replies to CfE: NGOs (3); Environmental organisations (2); Public authority (1). 
487 Interviews with third sector organisation (2). 

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Law 
framework 

or 

Issue(s) and explanations 

simplify the process. Each assessment will be available ahead of the next step of 
the  NECP  process.  For  example,  the  assessment  in  2027  will  be  available  to 
Member  States  when  they  need  to  prepare  their  next  draft  NECP  (by  January 
2028). However, this could create a lag in the feedback loop to Member States. 
In  the  example  mentioned,  the  Commission’s  assessment  will  be  about  years 
2021-2025,  and  will  not  consider  the  developments  in  the  most  recent  years 
(2026 and 2027) that could also inform the preparation of the next NECP 

Similarly, Member States shall submit to the Commission a compliance report for 
the LULUCF Regulation by 15 March 2027 for the period from 2021 to 2025, and 
by 15 March 2032 for the period from 2026 to 2030. Ensuring convergence post-
2030  would  be  needed,  i.e.  consistency  between  the  2030  horizon  and  longer-
term objectives 

EU 
governance 

economic 

According to four stakeholders, despite recent improvements, coherence between 
the climate and energy governance and the EU economic governance needs to be 
strengthened488  so  that  the  coordination  of  economic  policies  at  EU  level 
becomes an enabler for the achievement of ambitious EU climate and energy goals 

Aarhus 
Convention 

In  2021,  the  ACCC  found  the  Governance  Regulation  framework  to  be  partially 
non-compliant with the standards of public participation established by Article 7 
of the Convention. While it found that the EU met the requirements of Article 6(3) 
of the Convention with respect to NECPs, it held that EU had ‘not yet demonstrated 
that it has adopted either a proper regulatory framework or clear instructions to 
ensure that the other requirements [i.e. to ensure ‘early public participation, when 
all options are open’, and that ‘due account is taken of the outcome’] […] are met 
in the adoption of [NECPs]’489 

Despite  pledges  by  the  Commission  to  conduct  a  more  detailed  assessment  of 
Member  States’  compliance  with  Article  10  of  the  Governance  Regulation  in 
adopting the NECP updates, climate advocacy groups have criticised:  

-  The  Commission’s  acceptance  of  Member  States’  consultation 
proceedings  that  will  be  completed  only  after  the  finalisation  of  the 
NECPs490 

-  The  absence  of  an  explicit  reiteration  of  the  Aarhus  Convention’s 
requirements  under  Article  7  in  the  text  of  the  Governance 
Regulation491 

-  The  non-binding  nature  of  the  Commission’s  2022  guidance 

document492  

It is not clear in most NECPs if a Strategic Environmental Assessment (SEA) has 
been conducted or if there are plans to do so 

488 Replies to CfE: NGOs (2), Environmental organisation (1). Scoping interview with EU institution. 
489 Decision VII/8f of the Meeting of the Parties on compliance by the European Union with its obligations under 
the Convention adopted by the Meeting of the Parties at its 7th session, https://unece.org/env/pp/cc/decision-
vii8f-concerning-european-union 
490  Swords,  P.,  Comments  on  first  progress  report,  UNECE,  2023,  https://unece.org/sites/default/files/2023-
11/frCommVII.8f_C54_C96_29.10.2023.pdf 
491  EEB,  CAN  Europe  and  others,  A  revised  and  responsive  Governance  Regulation  Respecting  environmental 
democracy rights in climate planning. Joint NGO position paper on the revision of Regulation 2018/1999 on the 
Governance  of  the  Energy  Union  and  Climate  Action,  2024,  https://unece.org/sites/default/files/2024-
04/frObsVII.8f_CAN_others_29.03.2024_position_paper.pdf  
492 Ibid. 

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Law 
framework 

or 

Issue(s) and explanations 

One  third  sector  organisation  interviewed  mentioned  the  issue  of  access  to 
information/  accessibility  of  data  (e.g.  information  may  not  be  fully  or  easily 
available to support the public consultation) (see EQ6) 

The  structure  of  the  Governance  Regulation,  developed  from  the  five  dimensions  of  the 
Energy Union, may result in sectoral PaMs being poorly connected to relevant dimensions 
(e.g. transport measures for the energy efficiency dimension). This raises the question of 
how  best  to  combine  the  structure  of  the  five  dimensions  with  sectoral  approaches 
(scenarios, planning and policies are usually developed in this way) 493. 

Two  coherence  issues  were  raised  in  relation  to  specific  technical  aspects  related  to 
definitions or phrasing in the Governance Regulation and other contexts. The first is the 
different definitions for monitoring used for the ETS and for international reporting494. The 
second  is  the  phrasing  on  feedback  from  the  Commission  to  Member  States,  with  a 
difference  between  the  Governance  Regulation  (‘recommendations’)  and  the  European 
Climate Law (‘requirement for follow-up’) 495. 

One technical issue about reporting tools was raised by two national authorities496, namely 
the  need  to  make  the  EU  and  international  reporting  tools  interoperable  to  the  extent 
possible  in  order  to  reduce  reporting  burden.  One  example  is  the  possibility  to  pre-load 
PaMs data from the NECPRs (Governance Regulation) into the BTR (UNFCCC) format. The 
EEA provides exports to be used for other reporting obligations. 

5.2  How did the intervention make a difference and to whom? 

This  section  presents  the  findings  of  the  evaluation  on  the  EU  added  value  of  the 
Governance  Regulation,  based  on  a  synthesis  of  the  information  from  the  various  data 
collection  tasks,  including  desk  research,  CfE,  surveys,  interviews,  and  the  stakeholder 
event.  

5.2.1  EU added value 

Overall, the information indicates key areas where the Governance Regulation has provided 
added  value.  These  include:  the  harmonisation  of  planning  and  reporting  processes 
between  Member  States;  stimulating  stakeholders  within  countries  to  report  and  plan 
together; expanding the areas in which countries report and monitor; and the ability of the 
EU  to  check  national  ambitions  and  progress  towards  common  objectives.  However, 
stakeholders also highlighted limitations in the ability to hold Member States and the EU 
accountable  and  to  seek  access  to  justice  under  the  Regulation.  They  also  emphasised 
areas  where  coordination  efforts  could  be  streamlined  and  improved,  and  signalled  that 
the added value of the Governance Regulation’s planning and reporting processes depend 
on the Member State, both because some Member States had more advanced pre-existing 
planning and reporting frameworks, but also because some Member States engage more 
actively with the process.  

The  consultation  process  highlighted  the  difficulty  stakeholders  face  in  intuitively 
understanding  and  interpreting  the  EU  added  value  criterion,  creating  a  challenge  for 
nuanced insights. Many were unable to comment on the EU added value of the Governance 

493 Interview with third sector organisation (1). 
494 Interview with NCA (1). 
495 interview with NCA (1). 
496 Survey of national authorities (2). 

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Regulation during the interviews and a significant share of survey respondents also opted 
not  to  answer  these  questions.  This  may  reflect  the  relatively  recent  adoption  of  the 
Governance Regulation and/or stakeholders not yet fully understanding its requirements 
and procedures, as well as partial overlap with other evaluation criteria.  

Further details are provided in the answers to EQ12 to EQ15 below. 

5.2.1.1  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 
Governance Regulation’s planning, reporting and monitoring obligations?  

Stakeholders’ opinions on the added value of the Governance Regulation varied. Some saw 
the Regulation as a unifying structure for the Energy Union, facilitating a comprehensive 
governance  approach  and  consolidating  various  information  for  the  energy  transition. 
However,  opinions  differed  on  its  added  value  in  enhancing  policy  consistency  and 
coordination,  both  nationally  and  sub-nationally.  National  authorities  generally  view  it 
positively, while third sector and industry stakeholders have mixed or critical views. These 
perspectives  may  be  influenced  by  both  the  Governance  Regulation’s  design  and 
implementation,  and  the  existing  processes  in  each  Member  State.  Accordingly,  the 
analysis distinguishes between the Governance Regulation itself and implementation of the 
Regulation.   

In  their  survey  responses,  national  authorities  tended  to  indicate  that  the  Governance 
Regulation has contributed to more coordinated and consistent national energy and climate 
policies,  with  44 %  of  respondents  believing  this  was  achieved  to  a  very  large  or  large 
extent (see Figure 42). A further 28 % indicated that this was achieved to some extent, a 
small proportion thought this was not achieved at all (8 %), 8 % felt the question was not 
relevant or they did not know the answer, and 28 % (seven) left the question blank.  

Among third sector respondents, the perceptions were less positive. While 14 % (two out 
of  14)  felt  that  the  Governance  Regulation  contributed  to  more  consistency  and 
coordination  of  national  energy  and  climate  policies,  28 %  (four)  believed  it  was  not 
achieved at all, and a further 21 % (three) indicated that the Regulation only contributed 
to a small extent.  

Industry  stakeholders  provided  a  mixed  view.  Around  one-third  (36 %)  of  the  industry 
respondents  (five  out  of  14)  indicated  that  the  Regulation  contributed  to  increased 
consistency  and  coordination  to  a  large  extent,  while  14 %  (two)  and  21 %  (three)  of 
respondents indicated that the Regulation has not achieved this at all, or only to a small 
extent, respectively. 

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Figure 42. Respondents’ agreement with the statement ‘To what extent would you say that 
the Governance Regulation has contributed to more coordinated and consistent 
national energy and climate policies’ 

Source: ICF, based on targeted survey. 

One  participant  in  the  stakeholder  event  noted  that  before  the  Governance  Regulation 
there was no means to bring together the different strands of information needed for the 
energy transition497. The Regulation provided the architecture for the Energy Union and it 
requires an important ‘whole of government’ approach. The stakeholder argued that timing 
and template challenges should be considered ‘teething issues’, noting that it would not be 
wise to change the legislation before the sector has properly used it.  

Improved consistency in national energy and climate policies 498  

During  the  interviews  and  the  stakeholder  event,  stakeholders  highlighted 
several  areas  where  the  Governance  Regulation  has  supported  consistency  in 
Member  States’  policies.  Overall,  stakeholders  tended  to  agree  that  there  is  a 
notable  improvement  in  consistency  in  national  energy  and  climate  policies, 
although the size of that impact varies across Member States, depending on the 
processes already in place in each country. 

PaMs  data,  reported  under  the  Regulation,  provides  information  on  Member  States’ 
progress towards achieving climate and energy targets. These data also aid in identifying 
synergies, promoting policy coherence, and fostering transparency among Member States, 
thereby contributing to the Regulation’s added value. 

497 Contribution to the workshop by an industry representative (Wind Europe). 
498 This question entails consistency between the internal policies within Member States (e.g. between energy 
and climate policies), as well as the consistency between the policies of different Member States (e.g. between 
the energy/climate policies of country x and y).  

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At the same time, EEA reporting on PaMs signals several issues with data consistency 499. 
The most common discrepancy is between the implementation status and period (see EQ1) 
(e.g.  errors  where  the  end  year  has  already  passed).  Inconsistencies  may  also  arise 
between the implementation status and projection scenarios, typically in PaMs with a start 
year  close  to  the  reporting  year.  A  significant  share  of  the  inconsistencies  (76 %  of  the 
questions) are resolved during the QC process. In some cases, however, Member States 
are  reluctant to adjust  their reporting, which is generally linked to a  preference to  keep 
their original reporting and maintain the same rationale followed in the NECPs. 

Four  interviewees500  mentioned  that  the  comprehensive  reporting  and  planning 
mechanisms  introduced  under  the  Governance  Regulation  (e.g.  NECPs)  has  helped 
consistency,  as  these  plans  replace  and  aggregate  previously  scattered  sectoral  action 
plans.  This  process  seems  to  have  ensured  that  reporting  is  taken  more  seriously, 
according to one interviewee501. Two interviewees502 mentioned that the Regulation added 
significant  value  by  introducing  uniform  and  complete  reporting  in  structured  systems, 
which are central to achieving aligned coherent data that can be used to assess progress 
against targets. One of these stakeholders stressed that this system provides transparent, 
easily accessible data, significantly reducing duplication of work and incoherence between 
different reporting. They highlighted that while it is difficult to say whether the improved 
quality is attributable to the Governance Regulation, they have seen huge improvements 
in  Member  States’  methodologies  as  a  result  of  the  harmonised  reporting.  One  of  the 
participants in the workshop highlighted that the Regulation has enhanced consistency by 
allowing countries to set ‘clear short and mid-term goals, which are stable over time and 
largely independent of the political cycle’ 503. 

Three interviewees504 highlighted that the Governance Regulation has created consistency, 
with certain key data now collected by all countries. Most importantly, the EU added value 
is that this standardised approach and the associated data requirements are enforced. One 
respondent505  remarked  that  the  ability  to  quality  check  and  enforce  certain  standards 
across  EU  countries  is  specific  to  the  European  Commission,  as  it  would  be  difficult  for 
Member  States  to  coordinate  uniformly  applied  standards  or  quality  check  their  data 
against  these  standards  themselves.  Another  stakeholder  highlighted  the  value  of 
mandatory  templates,  which  allow  for  a  clearer  dialogue  between  and  within  Member 
States on their assumptions about developments in their country, for example506.  

Some  countries  had  well-established  national  planning  and  reporting  mechanisms  for 
climate  and  energy  policy  before  the  Governance  Regulation  was  adopted.  At  least  one 
interviewee (national authority) explained that the Governance Regulation serves more as 
a  reporting  tool  than  a  planning  tool,  and  has  not  provided  significant  added  value  in 
developing  new  PaMs 507.  However,  they  also  mentioned  that  even  in  those  cases,  the 

in 

in 

and 

energy 

Europe 

climate 

policies 

and  measures 

499 Dauwe, T., Vella, A., Sammut, J., Gu, Y., Gleeson, L., Young, K. and Perl, D., Overview of reported integrated 
national 
2023, 
https://www.eionet.europa.eu/etcs/etc-cm/products/etc-cm-report-2023-06   
500 Scoping interview with NCA (1): CZ; Interviews (3) with climate civil society organisations (Coalition for energy 
savings, WWF Europe, EUREC). 
501 Interview with climate civil society organisation (1) (EUREC). 
502 Scoping interview (1): EEA; comment during the workshop from a climate civil society organisation (Ecologic 
Institute). 
503 Point raised during the workshop by the LT Ministry of Energy. 
504 Scoping interviews (3): DG ENER, DG Environment (DG ENV), NCA (CZ). 
505 Scoping interview (1): EEA. 
506 Interview (1): research organisation (Ecological Institute in Berlin). 
507 Interview (1): NCA (NL: Netherlands Enterprise Agency - Ministry of Economic Affairs and Climate Policy). 

2023, 

EEA, 

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integration  of  various  existing  obligations  into  one  framework  made  the  process  more 
effective508. 

Improved coordination in national energy and climate policies 

Stakeholder  feedback  across  the  various  consultation  strands  shows  that  the 
Governance  Regulation  has  added  value  to  the  coordination  of  national  energy 
and  climate  policies,  but  there  is  room  for  stronger  coordination  with  sub-
national actors and between state-level actors.  

One interviewee commented that the added value of the Governance Regulation in terms 
of coordination depends on the manner in which targets are set509. In the 2020 framework, 
all targets were binding at national level, reducing the need for coordination, given that 
each Member State would have been subjected to an infringement procedure had they not 
achieved their targets. By contrast, the 2030 targets on RES and energy efficiency are not 
binding  at  national  level,  but,  rather,  at  EU  level.  According  to  the  stakeholder  (a  civil 
society organisation), this means that effective coordination is a prerequisite to ensuring 
that every Member State takes responsibility for their share of the effort to achieve this 
target510.  They  clarified  that  the  current  framework  of  EU-wide  2030  targets  would  not 
deliver much without the coordination efforts under the Governance Regulation, and the 
EU added value of the Regulation should be seen through this lens.  

Several  stakeholders  agreed  that  the  Governance  Regulation  adds  value  by  enabling 
Member  States  to  move  towards  a  common  goal.  For  example,  two  stakeholders 511 
highlighted that the Regulation improved cooperation and coordination between different 
national ministries, departments, and governmental agencies, and guided discussions on 
climate and energy within the country512. This coordination was particularly valuable where 
different  departments  did  not  previously  collaborate  at  the  same  level.  One  of  these 
stakeholders513 stated that the Governance Regulation has helped to bring key expertise 
and people together, creating a coherent whole from the different elements that comprise 
the policies. According to one stakeholder, the Regulation is a bridge between climate and 
energy  targets  and  Member  State  action,  and  they  doubted  whether  such  coordination 
would  otherwise  happen,  while  also  foreseeing  a  more  uneven  state  of  play  between 
Member States514. 

Three stakeholders515 highlighted that it would have been very burdensome for Member 
States individually to set up the processes and frameworks to coordinate the collection and 
reporting  of  data  as  the  common  templates  do516.  The  coordination  that  takes  place 
through the Governance Regulation can break silos between the complex policy areas of 
energy and climate and create a clear reference for all Member States, according to one 
EU institution517.  

Stakeholders  highlighted  that  access  to  other  countries  NECPs  supports  international 
cooperation  and  learning,  which  is  particularly  helpful  for  national  authorities518.  One 

508 Interview with NCA (1): Netherlands Enterprise Agency - Ministry of Economic Affairs and Climate Policy). 
509 Interview (1): climate civil society organisation (E3G). 
510 Interview (1): climate civil society organisation (E3G). 
511 Scoping interview with NCA (1): CZ. 
512 Interview with NCA (1): Netherlands Enterprise Agency- Ministry of Economic Affairs and Climate Policy). 
513 Scoping interview with NCA (1): Czechia. 
514 Interview (1): climate civil society organisation (CAN Europe). 
515 Interviews (3): Committee of the Regions, EEA, climate civil society organisation. 
516 Scoping interview (1): EEA. 
517 Scoping interview (1): Committee of the Regions. 
518  Interviews  with  NCAs  (2):  LT  (Ministry  of  Energy,  Ministry  of  Environment,  Lithuanian  Energy  Agency, 
Lithuanian  Environment  Protection  Agency),  BE  (Federal  Public  Service  of  Economy  –  Directorate-General 
Energy). 

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stakeholder  signalled  that  the  Governance  Regulation  forced  policymakers  to  consider 
policies from the perspective of the Energy Union dimensions, fostering a more integrated 
approach 519.  

The  potential  for  EU  added  value  from  improved  coordination  was  also  mentioned  by 
stakeholders in the context of multi-level stakeholder engagement, i.e. involvement of sub-
national actors (see EQ6.  How successful has the Regulation been in ensuring adequate 
multi-level and multi-stakeholder dialogue and consultation?EQ6.  How successful has the 
Regulation  been  in  ensuring  adequate  multi-level  and  multi-stakeholder  dialogue  and 
consultation?).  Stakeholders  noted  that  such  multi-level  coordination  could  be  more 
strongly anchored within the Governance Regulation520.  

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

Data on the number of PaMs reported each year show that more information is 
available  since  the  introduction  of  the  Governance  Regulation.  Stakeholders 
generally  agreed  that  the  planning  and  reporting  obligations  of  the  Regulation 
provide  additional  information  at  EU  or  national  level,  although  national 
authorities were somewhat divided.  

The survey divided this question into three sub-questions, covering: a) whether a Member 
State would have achieved the same level of planning and reporting in the absence of the 
Governance  Regulation,  b)  whether  the  Regulation  made  information  available  that 
otherwise  would  not  have  been  accessible  to  the  public,  and  c)  whether  the  Regulation 
made information available from other Member States that would otherwise not have been 
available to the respondent.  

Several  high-level  observations  can  be  made  based  on  reported  data  from  the  Member 
States. First, there has been a steady increase over time in the number of PaMs reported 
as part of each reporting cycle (see EQ1). In 2023, the number of reported single national 
PaMs  to  reduce  GHG  emissions  increased  since  the  last  reporting  cycle.  Member  States 
reported for the first time on national PaMs for all five dimensions of the Energy Union. Of 
the total number of PaMs (including both integrated reporting and reporting on GHG PaMs), 
68 % related to Union policy, signalling that a significant share of PaMs are tied to Energy 
Union policy. Despite the increase in the number of PaMs, the completeness of reported 
quantitative information on national PaMs did not improve (see EQ1) for either the achieved 
(ex post) and expected (ex-ante) effects on GHG emissions and their costs and benefits 
(see Figure 43). This prevents a comprehensive analysis of the impacts of existing national 
climate  policies  across  the  EU  and  makes  comparing  and  summing  ex-post  emission 
savings  a  highly  uncertain  exercise.  Information  on  renewable  energy  production  and 
energy savings (part  of the integrated reporting), which had to be  reported for the first 
time, was reported only anecdotally521. 

519 Interview with NCA (1): NL. 
520 Interview with civil society organisation (1). 
521 Dauwe, T., Vella, A., Sammut, J., Gu, Y., Gleeson, L., Young, K. and Perl, D., Overview of reported integrated 
national 
2023, 
https://www.eionet.europa.eu/etcs/etc-cm/products/etc-cm-report-2023-06   

and  measures 

policies 

climate 

Europe 

energy 

2023, 

EEA, 

and 

in 

in 

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Figure 43. Number  of  PaMs  with  reported  expected  (ex-ante)  and  achieved  (ex  post) 

effects 

Source:  EEA  reporting  on  integrated  national  climate  and  energy  policies  and  measures,  
https://climate-energy.eea.europa.eu/topics/policies-and-measures/climate-and-energy-policies-
and-measures/data 

The 2023 report by the European Topic Centre (ETC) on climate change mitigation shows 
the  potential  of  the  reporting  on  integrated  national  climate  and  energy  PaMs  as  a 
repository for PaMs across all dimensions of the Energy Union. However, there is still room 
for  improvement  on  the  completeness  of  this  information 522.  For  example,  information 
should be provided on the effects of these actions to identify successes and failures and 
support  a  knowledge  base  for  evidence-based  policy  decisions.  Member  States  should 
report  any  available  (quantitative)  information  on  GHG  emission  savings,  renewable 
energy production, or energy savings achieved or expected as a result of reported PaMs, 
either individually or for groups of PaMs.  

Despite some of these limitations, the baseline number of GHG PaMs reported before the 
Governance Regulation (2017), and the improved completeness in reporting of these PaMs 
from  2017  to  2019  seems  to  signal  that  the  Governance  Regulation  has  contributed  to 
increased  information  from  Member  States  about  their  climate  and  energy  PaMs.  The 
addition of integrated reporting in 2023 establishes the provision of information on PaMs 
in  all  five  dimensions  of  the  Energy  Union,  although  the  reporting  requirements  for  this 
information were almost entirely incomplete523.  

Data collected by the EEA on a range of indicators under Article 18(a) and 18(b) of the 
Governance Regulation indicate the completeness of Member States’ information provided 
as part of their obligations under the Regulation524. Member States consistently report on 
a number of mandatory aspects since 2017, such as updated projections, required sector 
split, required GHG split, a provision of parameters, and model factsheet description. Most 
are covered by all countries, or all countries except one or two. Romania (2019) did not 
report on any of the EEA data, for example, while others are individual missing entries. A 
notable exception is the sensitivity analysis, where, despite the reporting requirement, the 
number of countries doing so has fallen over time (25 countries in 2017, 23 in 2019, 19 in 

and 

energy 

climate 

policies 

and  measures 

522 Dauwe, T., Vella, A., Sammut, J., Gu, Y., Gleeson, L., Young, K. and Perl, D., Overview of reported integrated 
national 
2023, 
https://www.eionet.europa.eu/etcs/etc-cm/products/etc-cm-report-2023-06  
523 Ibid. 
524 Article 18 of Regulation 2018/1999: by 15 March 2021, and every two years thereafter, Member States shall 
report to the Commission information on: (a) their national policies and measures or group of measures as set 
out in Annex VI; and (b) their national projections of anthropogenic greenhouse gas emissions by sources and 
removals by sinks, organised by gas or group of gases (Hydrofluorocarbons and Perfluorocarbons) listed in Part 
2 of Annex V. National projections shall take into consideration any policies and measures adopted at Union level 
and shall include the information set out in Annex VII. 

Europe 

2023, 

EEA, 

in 

in 

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2021). There are several voluntary domains of reporting, including scenarios (WEM, WAM, 
WOM), the provision of indicators, and reporting on 2040. Many countries do not provide 
this information, but a general positive trend can be observed over time, with an increased 
share  of  countries  reporting  on  WAM  (59 %  in  2022  to  81 %  in  2023),  the  provision  of 
indicators (30 % in 2022 to 67 % in 2023), and reporting on 2040 (14 % in 2022 to 52 % 
in 2023). The increase in information provided voluntarily (pre- and post-Regulation) may 
signal  the  positive  impact  of  the  Regulation,  although  it  is  difficult  to  make  any  claims 
about causality. 

Planning and reporting in the absence of the Governance Regulation 

National authorities were divided on whether planning and reporting would have 
been  as  effective  in  the  absence  of  the  Governance  Regulation,  although  other 
stakeholders were more positive about its impact (see EQ2).   

Just  over  one-third  of  national  authorities  (10  out  of  27  respondents  in  the  survey) 
indicated that they would have achieved the same level of planning in the absence of the 
Governance  Regulation  (see  Figure  44).  These  national  authorities  were  from  Bulgaria, 
Croatia, Denmark, Finland, Germany, Poland and Slovenia, thus countries with a variety 
of systems (e.g. centralised and decentralised).  

Approximately  half  (52 %)  of  the  national  authorities  that  responded  to  the  survey 
indicated that they would not have achieved the same level of planning in the absence of 
the Governance Regulation. They were  from Austria, Belgium, Croatia, Cyprus,  Czechia, 
Germany, Hungary, Lithuania, Malta, the Netherlands, Spain and Sweden. In some cases, 
several different authorities from the same country responded to the survey, sometimes 
providing  opposing  views.  These  contrasting  opinions  could  also  reflect  varying 
interpretations of the question (e.g. respondents might not have interpreted the same level 
to mean that planning/reporting is identical), different perceptions of the added value of 
reporting  and  planning  under  the  Governance  Regulation  (e.g.  only  those  aspects  with 
which they are familiar), as well as different perspectives on what may have happened at 
a  national  level  had  the  Governance  Regulation  not  existed.  Three  national  authority 
respondents neither agreed nor disagreed, and five chose not to answer. 

Survey  respondents  representing  the  third  sector  tended  to  indicate  that  planning  and 
reporting in their Member State would not have been at the same level in the absence of 
the Governance Regulation (71 %, 10 out of 14). Only one (7 %) indicated that the same 
level of planning and reporting would have been achieved. Some respondents seemed to 
struggle with this question, as one neither agreed or disagreed (7 %), two did not know or 
the question was not applicable (14 %), and six did not answer at all. More specifically, 
one  out  of  six  academic  and  research  organisations  highlighted  that  its  Member  State 
(Germany) would have achieved the same level of planning and reporting in the absence 
of  the  Governance  Regulation,  while  the  other  five  (from  a  range  of  Member  States) 
disagreed  or  strongly  disagreed.  Thirteen  environmental,  energy,  and  climate  NGOs  or 
associations  were  less  able  to  answer  the  question:  six  did  not  answer,  five  (strongly) 
disagreed, one neither agreed nor disagreed, and one replied that the question was not 
applicable, or they did not know.  

The only industry representative to answer this part of the survey said that the question 
was not applicable, or they did not know.  

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Figure 44. Respondents’  agreement  with  the  statement  ‘Your  Member  State  would  have 
achieved the same level of planning and reporting if the Governance Regulation 
did not exist’ 

Source: ICF, based on targeted survey. 

Feedback from the interviews supports the assertion that the Governance Regulation added 
value to planning and reporting processes. Nine interviewees highlighted that the planning 
and reporting processes under the Governance Regulation are at least somewhat better 
post-  Regulation.  Interview  participants  highlighted  particular  added  value  from  the 
requirement  to  report  and  plan,  the  comparable  and  consistent  templates  for  reporting 
(with instructions), and the obligation to tie national-level planning into the EU targets 525. 
One  noted  that  reporting  on  strategies  is  far  more  detailed  under  the  Governance 
Regulation. Member States must put together PaMs that integrate different sectors in the 
economy to achieve targets, present data to measure impacts and gaps of policy measures, 
and present alternative or additional measures if they are deemed to fall short of targets526. 
The  templates  for  reporting  and  planning  were  mentioned  as  a  particular  added  value, 
helping  to  consolidate  plans,  goals  and  measures  consistently  across  countries527.  One 
respondent highlighted that the value added by the Governance Regulation differs across 
Member  States528.  In  countries  that  already  had  planning  and  reporting  obligations,  the 
Governance  Regulation  may  have  helped  to  harmonise  obligations  across  the  EU  by 
providing a common reporting template (which not all Member States find equally helpful). 
In  Member  States  without  such  planning  requirements  in  national  law,  the  Governance 
Regulation  provides  much  greater  added  value,  ensuring  that  they  develop  and  make 
publicly available plans to meet EU targets 529. 

Information  availability  within  Member  State(s)  in  the  absence  of  the  Governance 
Regulation 

525 Interviews (4): climate civil society organisations (EEB, E3G, Transport and Environment), NCA (LT: Ministry 
of energy, Ministry of environment, energy agency, environment protection agency). 
526 Interview with climate civil society organisation (1): Transport and Environment.  
527 Ibid. 
528 Interview with climate civil society organisation (1): (EEB). 
529 Ibid. 

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The  Governance  Regulation  has  increased  information  availability  by  requiring 
the publication of plans, reports and data by Member States that may not have 
done so otherwise and by requesting data on indicators that some Member States 
may not previously have collected or reported. 

Feedback  from  national  authorities  indicates  that  the  Governance  Regulation  has  had  a 
positive impact on the availability of information within the Member States, with 14 survey 
respondents (50 %) agreeing or strongly agreeing530 (see Figure 45). Five Member States 
(18 %)  disagreed 531,  six  (21 %)  neither  agreed  nor  disagreed532,  three  (11 %)  felt  the 
question was not applicable or did not know how to answer (two from Finland, one from 
Germany), and five did not respond (18 %). In some cases, multiple national authorities 
from  the  same  country  responded  to  the  survey,  with  conflicting  perspectives,  possibly 
reflecting  different  responsibilities  of  those  national  authorities  (energy  and  climate 
change). 

Third  sector  organisations  were  asked  a  slightly  different  question:  whether  the 
Governance Regulation has made available information that would otherwise not have been 
accessible  to  the  public.  Again,  the  responses  tended  to  show  that  the  Governance 
Regulation has added value in availability of information (see Figure 45). Eight out of 14 
respondents (57 %) agreed, including three climate NGOs, two research institutions, an 
industry  organisation,  an  academic  organisation,  and  a  civil  society  NGO.  Only  one 
respondent  disagreed,  three  neither  agreed  nor  disagreed,  two  did  not  know  or  the 
question was not applicable, and six did not reply at all. 

Figure 45. Respondents’ agreement on whether the Governance Regulation has improved 

availability of information to the public  

The Governance Regulation has made available information in 
your Member State which would otherwise not have been 
accessible to the public

National authorities (N=28)

2

12

6

4

1

3

Third sector (N=14)

8

3

1

2

Strongly agree
Disagree

Agree
Strongly disagree

Neither agree nor disagree
Do not know / Not applicable

Source: ICF, basesd on targeted survey. 

Interviewees highlighted the additional information available because of the Governance 
Regulation.  One  national  authority  from  Belgium  explained  that,  previously,  information 
was  not  typically  made  public  unless  someone  had  specifically  requested  it.  Under  the 

530 National authorities (14): BE, BG, CY, CZ, DE (2), ES, FR, HR (2), HU, MT, LT, SK.   
531 NCAs (5): DK, ES, FI, LV, PL.  
532 National authorities (6): AT, DK, ES, NL, SE (2). 

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information 

Governance  Regulation, 
improving  government 
transparency.  Another  NCA  stated  that  it  makes  more  information  and  data  available 
because  of  the  Governance  Regulation 533.  One  also  highlighted  that  some  of  the 
information accessible now would not be available without clear obligations such as those 
laid out in the Governance Regulation534.  

is  published  openly, 

Interviewees explained why the Governance Regulation has increased the availability and 
accessibility  of  information.  One535  mentioned  that  the  Regulation  required  countries  to 
collect  and  report  data  in  new  areas,  such  as  energy  poverty  and  the  role  of  energy 
subsidies (especially for fossil fuels). They explained that energy poverty was exacerbated 
by  Russia’s  war  of  aggression  against  Ukraine  (see  section  5.3),  which  might  have 
prompted increased reporting in the area anyway, but the obligation on Member States to 
report  across  these  domains  nevertheless  increased  the  information  available.  Several 
respondents noted the obligation to publish the information contained in NECPs, as well as 
better accessibility stemming from consolidation of all of this information in one place 536. 
Another  interviewee  stated  that  some  EU  countries  have  issues  with  regulations 
guaranteeing  access  to  information  or  data  transparency,  but  data  gathered  by  the 
European Commission are all publicly available and easily accessible, which is a huge step 
forward in public access537. 

Some respondents mentioned issues with the timeliness of information negatively affecting 
usefulness, as well as where certain information is published (e.g. NECPRs), and Member 
States compliance with reporting requirements (see section 6.1.1.1)538. 

Information availability from other Member States in the absence of the Regulation 

Stakeholders  highlighted  the  information  they  can  access  from  other  Member 
States as a particular area of added value from the Governance Regulation. This 
arises from being able to access other Member States’ plans and through EU-level 
reporting. 

The survey of national authorities asked respondents whether more information is available 
from  other  Member  States  because  of  the  Governance  Regulation.  Almost  all  (89 %) 
agreed  or  strongly  agreed,  suggesting  a  key  area  of  added  value.  Only  one  disagreed 
(Poland), one neither agreed nor disagreed (Finland), and one did not know (Germany). 
The  number  of  negative/uncertain  responses  was  lower  than  for  survey  questions 
EQ13.1539 and EQ13.2540, highlighting both the benefit and also the ease with which that 
benefit  can be  observed. The survey did not ask third sector  respondents this question, 
largely  because  many  respondents  were  EU-level  or  cross-country  stakeholders  (the 
information  in  EQ13.ii  includes  the  insights  from  this  stakeholder  group,  with  57 % 
agreeing that more information is available).  

Interviewees  tended  to  indicate  that  more  information  is  available  across  the  Member 
States as a result of the Governance Regulation. Respondents from the third sector pointed 

533 Interview with NCA (1): LT (Ministry of Energy, Ministry of Environment, Lithuanian Energy Agency, Lithuanian 
Environment Protection Agency). 
534 Interviews with climate civil society organisations (2): Transport and Environment, E3G). 
535 Interview with NCA (1): NL (Netherlands Enterprise Agency- Ministry of Economic Affairs and Climate Policy). 
536 Interviews with climate civil society organisations (5): Association ZERO, WWF Europe, Coalition for Energy 
Savings,  E3G);  Interview  with  NCA  (1):  LT  (Ministry  of  Energy,  Ministry  of  Environment,  Lithuanian  Energy 
Agency, Lithuanian Environment Protection Agency. 
537 Interview with climate civil society organisation (1): (E3G). 
538 Interviews with climate civil society organisations (9): Association ZERO, WWF Europe, Coalition for Energy 
Savings, E3G; EUREC, Association ZERO, Transport and Environment. 
539 EQ13.1: ‘Your Member State would have achieved the same level of planning and reporting if the Governance 
Regulation did not exist’. 
540  EQ13.2:  ‘The  Governance  Regulation  has  made  available  information  in  your  Member  State  which  would 
otherwise not have been accessible to the public’. 

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to the State of the Energy Union as a particular benefit, noting that such a report would 
not  be  possible  without  the  Governance  Regulation541.  One  respondent  from  a  national 
authority stated that NECPs and plans from other countries are useful to learn about best 
practices  and  are  used  as  references542.  They  also  mentioned  that  it  can  be  difficult  to 
compare countries, as they take very different approaches to their NECPs, and it would be 
useful if the documents were more comparable for the purposes of inter-country learning. 

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

Stakeholder  feedback  confirmed  that  the  Governance  Regulation  has  had  a 
positive effect on reporting  and data  availability  and  improved  predictability of 
Member  States’  energy  and  climate  policies.  However,  respondents  pointed  to 
delays in making data available, occasional incomplete data, and noted that data 
could be more transparent and accessible. EEA data on the timeliness of reported 
GHG  and  integrated  national  PaMs  indicate  a  similar  lack  of  timeliness  in 
reporting by the Member States (see EQ1). 

Data from EEA reports on integrated and GHG reporting show that a majority of Member 
States  have  consistently  missed  reporting  deadlines  on  PaMs  (except  in  2021),  which 
countries are expected to report on every two years, by 15 March (see Table 27). 

Table 27.  Timeliness of submissions (PaMs) 

Number of Member States meeting/missing the deadline 

2017 

2019 

2021 

2023 

Deadline met 

9 (32 %) 

9 (32 %) 

15 (56 %) 

11 (41 %) 

Deadline missed 

19 (68 %) 

19 (68 %) 

12 (44 %) 

16 (59 %) 

Source: ICF, based EEA reports from 2017-2023. 

Although 2021 saw a notable improvement in timeliness, the number of late submissions 
increased again in 2023. While information from previous reporting could be reused, the 
2023  submission  required  more  extensive  integrated  reporting  on  the  five  climate  and 
energy  dimensions,  as  well  as  on  new  annexes.  According  to  the  EEA,  this  could  have 
contributed  to  the  delay  in  submissions543.  In  addition,  the  new  webform  in  Reportnet 
demanded more learning time on data entry. Another explanation for delayed reporting is 
countries’ preference to link reporting of both GHG projections and PaMs. By the end of 
June 2023, Member States had to report a draft updated NECP, which, in some countries, 
may  have  impacted  the  political  process  of  submitting  data  under  these  annexes.  More 
extensive  reporting  necessitated  more  cumbersome  QA/QC  processes.  It  is  difficult  to 
predict  what  timeliness,  or  the  predictability  of  reporting,  would  have  looked  like  in  the 
absence of the Governance Regulation; however, after the introduction of the Regulation, 
there have been minor improvements in the share of Member States meeting the deadline. 
This share is an important marker, not just of predictability, but also transparency, as it 
gives  the  users  of  this  information  (e.g.  third  sector,  industry)  sufficient  opportunity  to 
digest, review and use this information in their work. 

541 Interviews with climate civil society organisations (2): Coalition for Energy Savings, WWF Europe. 
542 Interview with NCA (1): LT (Ministry of Energy, Ministry of Environment, Lithuanian Energy Agency, Lithuanian 
Environment Protection Agency). 
543 Dauwe, T., Vella, A., Sammut, J., Gu, Y., Gleeson, L., Young, K. and Perl, D., Overview of reported integrated 
national 
2023, 
https://www.eionet.europa.eu/etcs/etc-cm/products/etc-cm-report-2023-06  

and  measures 

policies 

climate 

Europe 

energy 

2023, 

EEA, 

and 

in 

in 

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On predictability, one contributor to the stakeholder event signalled that the Governance 
Regulation is important for countries to achieve climate and energy targets and marks an 
improvement  on  the  previous  situation 544.  They  noted  that  the  Governance  Regulation 
provides  investor  certainty,  while  gap-filling  mechanisms  provide  a  good  equilibrium 
between  ambition  and  predictability.  This  predictability  is  aided  by  maintaining  a  stable 
legal framework for 2030, and planning how to adapt it for 2040, as per the Regulation.  

The survey responses from national authorities showed a generally positive picture of the 
transparency and predictability provided by the Governance Regulation (see Figure 46). In 
total,  13  of  the  25  (52 %)  respondents  signalled  that  the  Governance  Regulation  has 
improved transparency and predictability to a large or very large extent. A further seven 
(28 %) said this has happened ‘to some extent’545 and two (8 %) to a small extent. One 
respondent (Austria) did not think the Regulation improved transparency and predictability 
at all, two (Finland, Germany) did not know or the question was not applicable, and seven 
did not answer (including all three respondents from Poland).  

The survey responses from the third sector mirrored those of the national authorities fairly 
closely (see Figure 46). Seven out of 17 respondents agreed or strongly agreed that the 
Governance  Regulation  has  improved  transparency  and  predictability  (41 %),  while  a 
further  eight  neither  agreed  nor  disagreed  (six)  or  believed  that  the  Regulation  has 
achieved this ‘to some extent’ (two). Only one respondent (a climate NGO) disagreed that 
the Regulation created additional transparency or predictability, and three did not answer 
at all. 

Compared to the replies from national authorities and the third sector, the response from 
industry  was  more  mixed.  One-third  of  industry  respondents  (33 %,  5  out  of  15 
respondents) said that transparency and predictability increased to a large extent (none 
to a very large extent), five (33 %) to some extent, and four (27 %) to a small extent. 
The final respondent indicated that the Governance Regulation has not achieved this at all 
(Latvia) and two respondents did not answer.  

544 NCA: DE. 
545  Transparency  and  predictability  have  improved:  BE,  BG,  CY,  DK,  ES,  FR,  FI,  HR  (2),  HU,  LT,  MT,  SK. 
Transparency and predictability have improved to some extent: CZ, DE, DK, ES (2), FI, NL, SE.  

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Figure 46. Respondents’ agreement on whether the Governance Regulation has improved 

transparency and predictability  

To what extent would you say that the Governance Regulation 
has contributed to national energy and climate policies being 
more transparent and predictable?

National authorities (N=25)

2

Third sector (N=14)

1

11

6

7

2

1

2

6

1

1

Industry (N=15)

5

5

4

To a very large extent

To a large extent

To some extent

Only to a small extent

Not at all

Do not know / Not applicable

Source: ICF, based on targeted survey. 

Interviewees  highlighted  the  strong  positive  effect  of  the  Governance  Regulation  on  the 
reporting and availability of data for policy-making in the Member States. This includes the 
publication of the NECPs and EU-wide datasets on the new e-platform (whose accessibility 
was particularly praised by one interviewee). One interviewee highlighted that stakeholders 
rely on NECPs to make strategic decisions, demonstrating how improved transparency and 
predictability of Member State policies can play a role in stakeholder decision-making546. 
Another547 mentioned the predictability of the NECPs as a factor in attracting investment, 
strengthened by the stable NECP framework. Two participants in the stakeholder event 548 
echoed that the Governance Regulation has added value to the availability of information, 
noting that the NECPs include new policies, as well as themselves being more innovative 
and integrated. 

One national authority explained the mechanism argued that the Governance Regulation 
has  achieved  this  positive  effect  by  standardising  reporting  processes,  ensuring  timely 
reporting,  fostering  coordination,  and  encouraging  public  access  to  information 549.  They 
mentioned  that  the  Governance  Regulation  helps  to  ensure  alignment  with  EU-wide 
objectives, creating a more cohesive and predictable policy landscape and noted that while 
the specific impact of the Governance Regulation varies depending on each Member State's 
prior practices, it has undoubtedly contributed to improving the overall transparency and 
predictability of energy and climate policies in the EU. 

546 Interview with NCA (1): BE (Federal Public Service of Economy – Directorate General Energy). 
547 Scoping interview with the Committee of the Regions. 
548 Stakeholder event responses: Committee of the Regions, RESCoop.EU, and WindEurope.  
549 Interview with NCA (1): NL (Netherlands Enterprise Agency - Ministry of Economic Affairs and Climate Policy). 

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Some stakeholders interviewed identified certain issues with the transparency of data. One 
national authority550 explained that while the information provided through the reporting 
tools is clear, the outputs are not, i.e. the Commission may understand the information, 
but stakeholders do not. They suggested that EU databases should be enhanced such that 
those who input data from the Member States can access, reuse, and forward the data, 
and  have  more  control  of  the  data  submitted.  They  also  suggested  that  features  could 
include tools to visualise the data, so that authorities can present what they are doing with 
the NECPs in an accessible way. The European Commission and the EEA already provide a 
variety  of  tools  through  which  the  public  can  access  (some  of)  the  data,  including 
assessments, visualisations, and a database. For example, several datasets reported in the 
NECPRs (Article 18 and 19 of the Regulation) can be accessed via the climate and energy 
platform551. The EEA Datahub also provides access to more detailed data552. 

An  international  environment  organisation  interviewed  pointed  to  differences  in 
transparency  between  different  reporting  processes  under  the  Governance  Regulation, 
arguing that the progress reports are not sufficiently accessible, which limits transparency 
and  tracking  progress  towards  targets553.  Under  the  Governance  Regulation,  Member 
States  are  required  to  make  the  integrated  NECPRs  public  (Article  17(7)),  while  the 
Commission is obliged to publish these reports on its e-platform to facilitate public online 
access  (Article  28)554.  Despite  this  provision,  Member  States  have  yet  to  make  this 
information available (e.g. Austria has not published the 2023 draft updated NECP, which 
was due in June 2023), or published the information late (22 of the 2023 draft updated 
NECP  submissions 555).  This  sentiment  was  echoed  at  the  stakeholder  event,  where  one 
contributor pointed to three main issues: (a)  sequencing in the reporting cycle (a delay 
between  reports  being  submitted  and  being  publicly  available556),  (b)  reports  are  often 
difficult to understand for non-experts, as they comprise numerous Excel tables, and could 
usefully  be  clarified  with  a  narrative  summary,  and  (c)  the  description  of  existing  and 
additional measures is missing or insufficiently detailed 557. One interviewee stated that the 
lack  of  detail  and  succinctness  of  some  of  the  NECPs  limits  the  transparency  and 
predictability in respect of Member States’ policies in practice558.  

The CfE highlighted the challenges faced by some stakeholders in accessing information 
and with transparency. Respondents highlighted that some draft NECPs and NECPRs were 
not made available to the public or were not made available at the right time559. Several 
reported that this limited the ability of the public to respond to the public consultation560.  

550 Interview with NCA (1): EE (Ministry of Finance; Estonian Environmental Centre). 
551  EEA,  Climate  and  energy  in  the  EU,  n.d.,  https://climate-energy.eea.europa.eu/topics/policies-and-
measures/climate-and-energy-policies-and-measures/data;  
552 EEA, EEA Datahub, n.d., https://www.eea.europa.eu/en/datahub  
553 Interview with environmental civil society organisation (1): WWF Europe. 
554  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,  amending  Regulations  (EC)  No  663/2009  and  (EC)  No 
715/2009 of the European Parliament and of the Council, Directives 94/22/EC, 98/70/EC, 2009/73/EC, 20131/EU, 
2012/27/EU and 2013/30/EU of the European Parliament and of the Council, Council Directives 2009/119/EC and 
(EU)  2015/652  and  repealing  Regulation  (EU)  No  525/2013  of  the  European  Parliament  and  of  the  Council, 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32018R1999 
555 The EEA PaMs database shows that, across 2017-2023, 59.9 % of submissions were late. 
556 Data go through a QA/QC process after being submitted. 
557 Stakeholder event response from a climate civil society organisation (1): CAN Europe. 
558 Interview with NCA (1): LT (Ministry of Energy, Ministry of Environment, Lithuanian Energy Agency, Lithuanian 
Environment Protection Agency). 
559 Replies  to CfE:  EEB,  the  European Renewable  Energies Federation,  the  Estonian Fund  for  Nature  (Estonian 
Green Movement, Green Liberty), Fertő tó Barátai Egyesület, and CAN Europe. 
560 Replies to CfE: EEB, CAN Europe. 

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The stakeholder consultations highlighted a further area of improvement: while NGOs are 
a key beneficiary of the increased transparency under the Regulation, the third sector in 
particular was not consulted well by Member States in developing these plans. This was 
very strongly  reflected in the CfE, where respondents highlighted that the provisions on 
public participation and transparency should be strengthened561.  

5.2.1.4  EQ15  -  What  is  the  added  value  of  the  Regulation  in  terms  of  ensuring 

accountability and access to justice? 

Stakeholders provided diverging views about the Governance Regulation’s added 
value  in  ensuring  accountability  and  access  to  justice.  According  to  some 
stakeholders,  mostly  national  authorities,  the  Regulation  has  enhanced 
accountability  and  access  to  justice  by  ensuring  that  data  are  reported  and  by 
creating  some  mechanisms  to  enforce  standards.  Third  sector  stakeholders 
disagreed, pointing to the lack of significant improvements in accountability and 
access to justice. These diverging perspectives may have (partly) arisen as a result of 
different  national  legislation  or  differences  in  the  implementation  and  adherence  to  the 
Governance Regulation, rather than its design.  

Survey responses reflected different perspectives on the added value of the Governance 
Regulation.  National  authorities  tended  to  have  a  positive  view  of  the  improvements  to 
accountability and access to justice generated by the Regulation (see Figure 47). Five of 
the  25  national  authorities  (20 %)  felt  the  Governance  Regulation  has  improved 
accountability and access to justice to a large or very large extent, while most (12) selected 
to  some  extent  (48 %).  Two  national  authorities  did  not  believe  that  the  Governance 
Regulation has enhanced accountability and access to justice at all, and six (24 %) did not 
know or found the question non-applicable.  

Third sector respondents were markedly less positive, with only two of the 14 respondents 
(14 %)  agreeing  that  the  Governance  Regulation  has  improved  access  to  justice  and 
accountability to a large extent (see Figure 47). A further three (21 %) agreed to some 
extent and another three (21 %) to a small extent.  Seven of the 14 (50 %) disagreed or 
strongly disagreed with the notion that access to justice and accountability has improved.  

Two of the 14 industry  respondents (14 %) agreed that the  Governance Regulation has 
improved access to justice and accountability to a very large extent or a large extent, and 
a further two (14 %) indicated this was achieved to some extent (see Figure 47). Four of 
the  14  (29 %)  selected  to  a  small  extent,  and  two  (14 %)  said  that  the  Governance 
Regulation has not enhanced access to justice and accountability at all.  

561 Replies to CfE: CAN Europe, ZERO – Association for the Sustainability of the Earth System, Climate Alliance, 
and Baltic environmental organisations. 

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Figure 47. Respondents’ assessment of Governance Regulation impact on access to justice 

and accountability 

Source: ICF, based on targeted survey. 

Third sector respondents were asked additional questions to gain more detailed insights 
into their perceptions of the extent to which the Governance Regulation has enhanced the 
accountability of Member States and the EU (see Figure 48).  

Three  of  the  17  respondents  (18 %)  agreed  that  public  and  private  actors  are  able  to 
access justice to hold the government accountable for its obligations under the Governance 
Regulation, while another three (18 %) were neutral. Six of the 17 (35 %) disagreed or 
strongly disagreed, and a significant share (29 %) did not know  or the question did not 
apply.  

Third  sector  stakeholders  were  asked  whether  the  Governance  Regulation  provides 
adequate mechanisms to hold Member States and the EU accountable for their obligations, 
to  which  a  large  majority  disagreed  (50 %)  or  strongly  disagreed  (29 %).  Only  one 
respondent (7 %) agreed, and another (7 %) neither agreed nor disagreed.  

Third sector stakeholders were asked whether the Governance Regulation supports access 
to justice for public and private stakeholders. This question received slightly more positive 
answers, with one of the 14 respondents agreeing (7 %) and three neither agreeing nor 
disagreeing (21 %). However, eight (58 %) disagreed or strongly disagreed, two (14 %) 
did  not  know  or  the  question  did  not  apply,  and  three  did  not  answer.  These  survey 
responses suggest that a majority of third sector respondents (57 %) believe that there 
has been some improvement in the level of accountability and access to justice under the 
Governance Regulation, but that current accountability mechanisms and access to justice 
for public and private actors under the Governance Regulation require improvement. The 
low response rate to the survey prevents robust conclusions, however. 

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Figure 48. Respondents’ agreement on Member States’ and EU accountability 

Source: ICF, based on survey of third sector organisations.  

The  interviews  provided  some  further  context  to  the  added  value  of  the  Governance 
Regulation. One stakeholder562 mentioned that the EU has the ability to check the quality 
of Member State data and request improvements, another noted countries must include 
even those topics they did not want to address563, and another stated that planning and 
reporting obligations ensure that countries are reaching targets they would not otherwise 
reach 564  (possibly  driven  by  certain  funding  being  conditional  on  aspects  of  the  NECP). 
These  insights  echo  the  main  objectives  of  the  legislation,  which  include  ‘establishing  a 
governance mechanism to […] ensure the timeliness, transparency, accuracy, consistency, 
comparability,  and  completeness  of  reporting’565.  There  are  quality  check  procedures  in 
place, including QA and QC elements (e.g. Article 18) where good QA practices include a 
preliminary deadline and final deadline for inventories. However, while structured digital 
reporting allows for the comparability of Member State data and focuses on improvements 
in  data  quality  over  time,  it  could  be  enhanced  through  more  formalised  legally  binding 
quality  checking  procedures.  While  the  Governance  Regulation  mentions  QA  and  QC 
procedures (Articles 18, 37 and 39), defines these processes (definitions 16 and 17), and 
ascribes  QA  and  QC  responsibilities  to  the  EEA,  it  does  not  specify  that  Member  States’ 
reported  information  needs  to  pass  such  quality  processes,  nor  what  those  processes 
should constitute (e.g. best practices). One stakeholder acknowledged that the gap-filling 
mechanism is an area of concern, as there is little the EU can do when Member States do 
not fulfil the requirements566. According to two interviewees, the fact that the NECPs are 

562 Scoping interview with EEA. 
563 Interview with NCA (1): NL (Netherlands Enterprise Agency - Ministry of Economic Affairs and Climate Policy). 
564 Scoping interview with DG ENV. 
565  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,  amending  Regulations  (EC)  No  663/2009  and  (EC)  No 
715/2009 of the European Parliament and of the Council, Directives 94/22/EC, 98/70/EC, 2009/73/EC, 20131/EU, 
2012/27/EU and 2013/30/EU of the European Parliament and of the Council, Council Directives 2009/119/EC and 
(EU)  2015/652  and  repealing  Regulation  (EU)  No  525/2013  of  the  European  Parliament  and  of  the  Council, 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32018R1999 
566 Scoping interview with DG ENER. 

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publicly  available  allows  stakeholders  to  hold  Member  States  accountable  if  they  do  not 
fulfil the plans567. 

Several  stakeholders  suggested  in  the  interviews  and  the  CfE  that  there  should  be  a 
provision in the Governance Regulation granting access to justice at national level568. They 
pointed to the lack of a concrete and direct right of access to justice in the legal text of the 
Regulation  to  challenge  NECPs  or  LTSs  before  national  courts569.  In  addition,  the 
Commission’s recommendations are non-binding and the application of access to justice 
provisions does not seem consistent across Member States570. Respondents suggested that 
the  Governance  Regulation  should  allow  members  of  the  public  to  challenge  NECPs  and 
LTSs if they are in breach of any requirements laid out in the Regulation, as well as any 
substantive  requirements  of  European  environmental  law571.  A  number  of  respondents 
flagged the uneven application of access to justice across the Member States572. Making 
the  right  to  access  to  justice  explicit  in  the  Governance  Regulation  would  be  helpful  in 
addressing such issues573. 

5.3  Is the intervention still relevant? 

This section presents the findings of the evaluation on the  relevance of the Governance 
Regulation. It draws on evidence from the various strands of data collection, including the 
desk research, CfE, surveys, interviews and stakeholder event. 

5.3.1  Relevance 

The  evidence  indicates  that  the  Governance  Regulation's  core  objective  of  providing  a 
governance  structure  that  enables  and  pushes  Member  States  to  commit  and  deliver 
ambitious climate targets remains relevant. Indeed, the Governance Regulation seems to 
have become more relevant, given the increasing urgency of addressing climate change, 
the  growing  need  for  climate  action  (mitigation  and  adaptation),  and  the  increasingly 
complex  needs  to  be  addressed  by  Member  States'  energy  and  climate  policies.  At  the 
same time, the Regulation’s governance mechanisms do not sufficiently address some of 
the  issues  that  have  come  to  the  forefront  of  energy  policy,  for  example  due  to  recent 
geopolitical  and  legislative  developments.  This  may  hinder  the  Regulation’s  ability  to 
respond fully to emerging needs in European energy and climate policy. 

EU  energy  policy  pursues  multiple  objectives,  grouped  into  the  five  dimensions  of  the 
Energy Union. Achieving these objectives poses an enormous challenge to legislators and 
administrations at all levels of governance. 

Within  this  broader  regulatory  challenge,  the  Governance  Regulation  was  intended  to 
address  two  main  problems:  the  perceived  inadequacy  of  existing  national  and  EU-level 
policies to achieve climate and energy targets; and poor conformity of existing planning, 
reporting  and  monitoring  obligations  with  the  principles  of  Better  Regulation574.  The 
Governance Regulation was designed with the following objectives in mind: 

567  Interview  with  NCAs  (2):  BE  (Federal  Public  Service  of  Economy  –  Directorate  General  Energy),  NL 
(Netherlands Enterprise Agency- Ministry of Economic Affairs and Climate Policy). 
568 Replies to CfE: CAN Europe, EEB, WWF European Office, Transport and Environment); Interviews with CAN 
Europe, WWF Europe, Transport and Environment, EEB. 
569 Replies to CfE: CAN Europe and WWF European Office; Interviews with CAN Europe, EEB, and WWF Europe. 
570 Replies to CfE: CAN Europe and WWF European Office. 
571 Replies to CfE: EEB.  
572 Interviews with CAN Europe, EEB, Transport and Environment. 
573 Interviews with Transport and Environment, CAN Europe, EEB. 
574  European  Commission,  Impact  Assessment  accompanying  the  document  Proposal  for  a  Regulation  of  the 
European  Parliament  and  the  Council  on  the  Governance  of  the  Energy  Union,  amending  Directive  94/22/EC, 
Directive 98/70/EC, Directive 2009/31/EC, Regulation (EC) No 663/2009, Regulation (EC) No 715/2009, Directive 
2009/73/EC, Council Directive 2009/119/EC, Directive 2010/31/EU, Directive 2012/27/EU, Directive 2013/30/EU 

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  To enable and ensure the achievement of the objectives and targets of the Energy 
Union in line with the 2015 Paris Agreement, in particular, the targets of the 2030 
Framework for Climate and Energy, in the field of GHG emission reduction, energy 
from renewable sources and energy efficiency (Article 1(a); Recitals 1, 12, 16, 18); 
  To facilitate cooperation and coordination of regional, national and local climate and 

energy policies (Article 1(b); Recitals 3, 12, 23); 

  To ensure compliance by the EU and its Member States with international (UNFCCC 

and Paris Agreement) commitments (Article 1(c)); 

  To  unlock  private  investment  and  economic  growth  by  promoting  regulatory 

predictability and stability (Article 1(d); Recitals 12, 34, 35); 

  To promote accountability through transparency and monitoring (Recital 12); 
  To  reduce  the  administrative  burden  by  integrating  and  streamlining  planning, 

reporting, and monitoring obligations (Recitals 12, 23, 24, 70). 

Stakeholders unequivocally confirmed that these objectives were very relevant at the time 
the  Regulation  was  adopted  to  coordinate  efforts  to  meet  increasingly  complex  and 
ambitious climate targets575. Several stressed that the Governance Regulation remains a 
key piece of EU legislation today 576.  

Although the Governance Regulation is a relatively new instrument, major legislative and 
geopolitical changes following its adoption have reshaped policy priorities and highlighted 
different  issues  and  needs  that  may  not  be  adequately  addressed  by  the  mechanisms 
established by the Regulation.  

5.3.1.1  EQ16 - Are the Member States’ and Commission’s planning, reporting, and 
monitoring obligations under the Governance Regulation still relevant in 
view of legislative developments? 

The EU energy and climate acquis has undergone important developments since 
the  adoption  of  the  Governance  Regulation  in  2018,  notably  the  Fit  for  55 
package.  The  Governance  Regulation  is  primarily  a  procedural  framework  that 
does  not  itself  set  specific  targets,  somewhat  safeguarding  its  relevance. 
However, certain themes in recent legislation need to be better addressed in the 
‘products’ adopted under the Governance Regulation, such as the NECPs.  

The  legal  framework  for  energy  and  climate  policy  in  the  EU  has  undergone  significant 
changes  since  the  Governance  Regulation  was  adopted  (see  section  5.1.3.1).  While  the 
Regulation itself was amended in 2019, 2021 and 2023, an important aspect of evaluation 
is the extent to which its objectives remain relevant in the context of a changing political 
and legislative context. 

The survey answers suggest that perceptions of this issue differ considerably between third 
sector actors and Member States’ competent authorities, with respondents from the third 
sector  holding  a  far  more  negative  view  (see  Figure  49).  The  majority  of  national 
authorities  indicated  that  the  provisions  and  obligations  of  the  Governance  Regulation 
remain  relevant  and  up  to  date  in  light  of  both  EU  legislative  developments  (13  of  25 
respondents agreed and seven disagreed) and international legislative developments (14 
of 25 respondents agreed and three disagreed).  By contrast, half of the respondents from 
the third sector disagreed. 

and Council Directive (EU) 2015/652 and repealing Regulation (EU) No 525/2013, SWD(2016) 394 final, p. 11,  
https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52016SC0394&from=FR 
575  Interviewees  from  national  authorities,  EU  institutions,  and  civil  society  organisations.  While  not  all 
stakeholders  explicitly  expressed  views  on  the  initial  relevance  of  the  Governance  Regulation,  it  was  not 
challenged by any interviewee. 
576 Interviews with EU institutions, two environmental civil society organisations, and a national authority (EE, 
specifically highlighted the importance of NECPs).  

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Figure 49. Respondents’ agreement with the statement ‘The provisions and obligations of 
the Governance Regulation remain relevant and up to date in light of’: 

... EU legislative developments

National
authorities
(N=27)

13

5

7

2

Third sector
(N=14)

4

3

2

5

... international legislative 
developments

National
authorities
(N=27)

14

4

3

6

Third sector
(N=14)

3

3

3

4

1

Strongly agree

Agree

Neither agree nor disagree

Disagree

Strongly disagree

Do not know / Not applicable

Source: ICF, based on targeted survey.  

Replies  to  the  CfE  suggested  that  the  Governance  Regulation  would  benefit  from  being 
updated to reflect the latest targets and legislative developments577. More specifically, its 
relevance is limited by the fact it does not reflect elements introduced by RED II and the 
EED578.  Interviewees  from  civil  society  organisations,  as  well  as  survey  responses  from 
some national authorities,  shared that view, naming the Fit for 55 package, REPowerEU 
and  the  RRF  as  major  legislative  changes  not  sufficiently  reflected  in  the  Governance 
Regulation (see Figure 49).  

The  Governance  Regulation  does  not  prevent  Member  States  from  including  additional 
aspects in their reporting. Indeed, the Commission has provided guidance on how to take 
into  account  post-Governance  Regulation  policies  such  as  the  Fit  for  55  package, 
REPowerEU,  and  international  developments  such  as  the  Glasgow  Climate  Pact 579. 
However,  interviewees  from  civil  society  and  EU  bodies  suggested  that  these  issues  are 
not always adequately reflected in practice. 

Some  civil  society  stakeholders  called  for  an  update  of  the  targets580  referenced  in  the 
Governance  Regulation  in  line  with  the  Fit  for  55  ambitions  (since  amended  through 
Directive  (EU)  2023/2413581).  Others,  however,  argued  that  the Governance  Regulation 
itself is not intended to define such ambitions, but rather to guide the process by which 
Member States work towards their achievement. As targets might need to be updated to 
keep  pace  with  policy  developments,  how  the  Governance  Regulation  refers  to  specific 
targets should be considered582.  

plans, 

577 Replies to CfE: Civil society organisations (8); Business associations (2); Environmental organisations (3); EU 
citizen (1); Public authority (2) Other (1); Academic (1). 
578 Replies to CfE: Civil society organisations (2); Business associations (2); Public authorities (2); Other (1). 
579 Commission Notice on the Guidance to Member States for the update of the 2021-2030 national energy and 
climate 
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52022XC1229(02)    
580  Stakeholders  specifically  referred  to  the  Union-wide  GHG  emission  reduction  targets,  as  well  as  renewable 
energy targets. 
581  Directive  (EU)  2023/2413  of  the  European  Parliament  and  of  the  Council  of  18  October  2023  amending 
Directive (EU) 2018/2001, Regulation (EU) 2018/1999 and Directive 98/70/EC as regards the promotion of energy 
from renewable sources, and repealing Council Directive (EU) 2015/652, PE/36/2023/REV/2, OJ L, 2023/2413. 
582 Scoping interview with EU institution. 

495/02, 

2022/C 

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A  different  issue  is  the  relevance  of  the  plans  produced  by  the  Member  States  and  the 
European Commission and whether the frequency of updates is sufficient to ensure their 
continued  relevance.  Several  stakeholders583  argued  that  the  Commission’s  2018  Long-
Term Strategy, adopted under Article 15(2) of the Governance Regulation, is no longer in 
line with the policy landscape. One academic researcher interviewed noted that the biennial 
progress reports have proven useful in the context of changing parameters, such as higher 
ETS certificate prices and resulting revenues for Member States. 

The rapid evolution of the legislative landscape of EU climate and energy policy since the 
adoption of the Governance Regulation, while leading to certain coherence problems, has 
arguably increased the need for coordination, transparency and accountability instruments, 
as  envisaged  by  the  Regulation,  as  well  as  streamlining  obligations  to  minimise 
administrative burdens. This makes these objectives even more relevant. 

Scope of the Governance Regulation and its mechanisms 

While the Governance Regulation was not designed to set specific policy targets per se, it 
was intended to define the scope of issues that Member States (and the Commission) need 
to plan for and give account of, as well as the specific indicators to be reported on. Several 
stakeholders reflected on the relevance of this agenda-setting function of the Governance 
Regulation  in  the  context  of  changing  policy  priorities.  Some  argued  that  certain  issues 
highlighted in the more recent climate and energy acquis are not yet, or not sufficiently, 
addressed by the mechanisms of the Governance Regulation:  

  Economic  governance:  The  economic  and  industrial  dimension  of  the  green 
transition is an important challenge that some stakeholders felt is not sufficiently 
addressed  in  the  plans  and  reports  under  the  Governance  Regulation.  While 
envisaged  in  the  Regulation,  information  on  investment  needs  and  sources  for 
financing are insufficient to identify investment and/or financing gaps, and a solid 
assessment  of  the  macroeconomic  impact  of  the  PaMs  included  in  the  NECPs  is 
lacking584;  

  Indicators on the principle of energy sufficiency are lacking in the NECPs, according 
to one climate civil society organisation interviewed and four replies to the CfE 585; 
  Grid deployment and electrification issues should be enshrined in the Governance 
Regulation,  according  to  industry  representatives  and  one  interviewee  from  a 
climate think tank; 

  Climate  adaptation  measures  need  to  be  better  covered  by  the  Governance 
Regulation,  according  to  one  third  sector  organisation  interviewee,  particularly  in 
respect of information on measures already implemented by Member States586; 
  Six replies to the CfE587 highlighted that the Governance Regulation lacks provisions 
on access to justice, although some mentioned that the NECPs and LTSs are subject 
to  the  Aarhus  Convention,  which  grants  access  to  environmental  information  and 
justice. 

583 Replies to CfE: Civil society organisation (1); Environmental organisations (1); Academic (1); Interview with 
one civil society organisation. 
584 Submission by European Commission. 
585 Interviews with civil society organisation (2); Business associations (2); Public authorities (2); Other (1). 
586 Submission by EU institution. 
587 Replies to CfE: Civil society organisation (3); Environmental organisations (2); Academic (1). 

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5.3.1.2  EQ17 - How well has the governance mechanism set out by the Regulation 
responded  to  socioeconomic,  environmental,  and  geopolitical  changes 
and risks?  

The  Governance  Regulation’s  core  objective  of  facilitating  climate  action  is 
becoming ever more urgent amid emerging scientific evidence. The energy crisis 
triggered by Russia’s war of aggression against Ukraine recalibrated priorities in 
energy  policy  and  highlighted  energy  security  and  the  social  dimension  of  the 
energy transition. 

The relevance of the Governance Regulation was also assessed for its responsiveness to 
exogenous  risks  and  changes  across  socioeconomic,  environmental  and  geopolitical 
domains. Such changes are difficult to anticipate and raise the question of how to strike 
the  right  balance  between  more  detailed  and  prescriptive  governance  and  retaining 
sufficient flexibility to enable Member States to respond appropriately to changing policy 
priorities and objectives. 

Survey results indicated that NCAs and civil society are divided on whether the governance 
mechanism  set  out  by  the  Governance  Regulation  has  adequately  responded  to 
socioeconomic, environment and geopolitical developments and crises since its adoption 
(see Figure 50). While national authorities tended to take a neutral to positive stance588, 
third  sector  respondents  overwhelmingly  found  the  response  of  the  Regulation’s 
governance mechanism inadequate. 

Figure 50. Stakeholders’  views  on  the  response  of  the  Governance  Regulation’s 

mechanisms to non-legislative developments 

The governance mechanism set out by the Governance Regulation 
has adequately responded to socio-economic, environmental and 
geopolitical changes and crises.

National authorities (N=26)

6

10

3

7

Third sector (N=14)

2

9

1

2

Strongly agree
Disagree

Agree
Strongly disagree

Neither agree nor disagree
Do not know / Not applicable

Source: ICF, based on targeted survey. 

Looking ahead and judging the potential for the Governance Regulation to respond to long-
term  challenges,  the  picture  is  similar,  if  slightly  more  polarised  on  the  part  of  national 
authorities, and more negative on the part of third sector respondents (see Figure 51). Of 
the 27 national authorities that responded to the survey, 10 agreed589 that the provisions 
and obligations of the Governance Regulation appear fit for the future, including beyond 

588 Agree: BG, ES (3), HU, SK; Neither agree nor disagree: AT, CY, CZ, DE, FR, HR (2), LT, MT, SE (2); Disagree: 
BE, DK (1), NL.  
589 Survey of national authorities: BG, CZ, DE (2), ES (2), FR, HR (1), HU, LT, NL, SK.    

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2030, seven disagreed590 and eight were neutral591. By contrast, only two of the 14 third 
sector organisations that responded to the survey agreed, while 12 disagreed (five strongly 
disagreed). 

Figure 51. Stakeholders’  views  on  the  relevance  of  the  Governance  Regulation  to  future 

challenges 

The provisions and obligations of the Governance Regulation 
appear fit for the future, including beyond 2030.

National authorities (N=27)

10

8

6

1

2

Third sector (N=14)

2

7

5

Strongly agree
Disagree

Agree
Strongly disagree

Neither agree nor disagree
Do not know / Not applicable

Source: ICF, based on targeted survey. 

The environmental, geopolitical and socioeconomic context of the Governance Regulation 
has  significantly  evolved  since  its  adoption  and  has  grown  increasingly  complex  and 
challenging.  These  developments  have  led  to  a  certain  recalibration  of  energy  policy 
priorities  (e.g.  supply  security),  as  well  as  highlighting  existing  challenges  (e.g.  energy 
poverty). The need for coordinated policy action has grown accordingly. The ways in which 
exogenous factors have impacted the initial objectives of the Governance Regulation and 
the needs address/not addressed by the Regulation are discussed below.  

Environmental changes and risks 

As the outlook for climate change and its associated impacts is both worsening 
and becoming more clear-cut, the core objective of the Governance Regulation – 
to enable and support climate action – is more relevant than ever.  

The  IPCC  recently  released  its  Sixth  Assessment  Report,  which  summarises  scientific 
knowledge on climate change. The report not only adds certainty to the climate projections 
available at the time the Governance Regulation was drafted, but predicts higher climate-
related risks with greater confidence than the previous IPCC assessment report in 2014 592.  

In  view  of  this  increasing  urgency,  the  Governance  Regulation’s  primary  purpose  of 
providing a governance mechanism that enables and encourages joint energy and climate 
action in the EU and helps to ensure the achievement of GHG reduction targets is more 
relevant than ever. This was acknowledged by several of the replies to the CfE (including 

590 Survey of national authorities: DE (2), DK (2; 1 strongly disagreed), FI (3), MT, SE (2).  
591 Survey of national authorities: AT, BE, CY, DE (3), ES (2), HR (2), SE (1).  
592 IPCC, Climate Change 2023: Synthesis Report. Contribution of Working Groups I, II and III to the Sixth 

Assessment Report of the Intergovernmental Panel on Climate Change, 2023, p. 68. 

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several  third  sector  organisations  and  a  citizen  from  Spain),  as  well  as  by  interviewees 
(including national authorities and third sector organisations).  

Several additional or revised pieces of legislation have been adopted since 2018 to better 
align with these scientific projections, including an upwards revision of the 2030 EU-level 
targets. However, although this required updates to realign the targets referenced in the 
Governance Regulation, it does not impact the relevance of the Governance Regulation’s 
energy and climate objectives as such 593. 

Geopolitical changes and risks 

Russia’s war of aggression against Ukraine disrupted EU energy policy in several 
dimensions. While lending additional relevance to the Energy Union’s objectives 
and  accelerating  the  need  for  a  clean  energy  transition,  it  also  prompted  a 
recalibration of immediate policy priorities and highlighted transition challenges. 

Russia’s  aggression  made  European  policymakers  acutely  aware  of  the  risks  associated 
with excessive and undiversified reliance on energy supplies from particular third countries. 
It acted as a catalyst for the transition away from fossil fuel imports and towards a more 
diversified energy supply based on RES.  

As a result of this additional impetus, targets and projections for the share of renewables 
in  the  EU's  energy  mix  were  revised  significantly  upwards,  most  notably  as  part  of 
REPowerEU, which proposed to upgrade the renewable energy target to a 45 % share of 
renewables by 2030, up from the 40 % target previously envisaged594. The IEA has also 
revised its five-year main case forecast for renewable electricity capacity expansion in the 
EU for 2022, up 35 % compared to the previous year’s estimate595. 

At  the  same  time,  the  shift  away  from  Russian  fossil  fuels  and  the  energy  crisis  have 
brought to the fore issues not currently sufficiently reflected in plans and reports under the 
Governance Regulation framework. This includes energy security, for example the planning 
for Liquefied Natural Gas (LNG) imports and consumption volumes to replace Russian gas 
imports,  which,  according  to  one  climate  think  tank  interviewed,  need  to  be  covered  in 
more detail in the Governance Regulation.  

The spiralling of energy prices in the wake of Russia’s war of aggression against Ukraine 
and the ensuing Western sanctions highlighted the significance of the social dimension of 
the energy transition. Energy-intensive industries likewise grappled with the energy supply 
crisis, particularly in regions with vulnerable energy markets, such as Central Europe, as 
noted by one industry interviewee. 

Enhanced  energy  efficiency  is  seen  by  some  as  a  means  to achieve  climate  targets  and 
simultaneously  achieve  the  geopolitical  objective  of  economic  resilience.  Some  see  the 
focus  on  energy  ‘efficiency’  as  inaccurate,  such  as  one  civil  society  interviewee,  who 
proposed instead to strive explicitly for a reduction of energy consumption (related to the 
concept of energy sufficiency discussed above). 

Two  interviewees  from  the  European  Commission  and  civil  society  highlighted  the 
exceptional  character  of  the  crises  and  noted  that,  as  an  instrument,  the  Governance 
Regulation cannot be expected to  respond to  all volatile developments.  The civil society 
interviewee argued that imminent crises require hands-on political rather than regulatory 
action. 

Socioeconomic changes and risks 

593 Interviews with NCAs (2) and EU institution (1). 
594 IEA, Renewables 2022, 2022, https://www.iea.org/reports/renewables-2022  
595 IEA, Upward revisions to renewable capacity expansion forecasts from Renewables 2021 to Renewables 2022, 
2022, 
https://www.iea.org/data-and-statistics/charts/upward-revisions-to-renewable-capacity-expansion-
forecasts-from-renewables-2021-to-renewables-2022  

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The energy supply crisis following Russia’s war of aggression against Ukraine and 
the COVID-19 pandemic highlighted the social and economic challenges that need 
to be addressed if climate change and just transition goals are to be met in the 
long  term.  In  addition,  a  shortage  of  skilled  labour  threatens  to  hamper  the 
technical execution of the energy transition across Member States. Stakeholder 
consultations suggest that socioeconomic issues are not yet adequately covered 
by the governance mechanisms of the Regulation. 

Since  the  adoption  of  the  Governance  Regulation,  economic  conditions  in  many  EU 
countries  have  significantly  shifted  as  a  result  of  the  COVID-19  pandemic,  inflationary 
pressures, energy supply constraints and associated price increases, and increasing energy 
poverty596. Member States and the EU (notably through REPowerEU) took action to address 
some of these emerging risks, and the European Commission encouraged Member States 
to take into account and plan for socioeconomic issues in their updated NECPs597. 

Nevertheless,  certain  socioeconomic  issues  are  not  yet  sufficiently  reflected  in  the 
governance mechanisms of the Regulation, nor in Member States' actions. One interviewee 
from a German civil society organisation noted that the assessment of energy poverty in 
the NECP, for instance, is limited to the assumption that there is a legal right not to be 
subject to energy poverty in Germany. Similarly, the Commission’s assessment of the draft 
updated  NECPs  found  that  ‘most  NECPs  still  lack  structural  PaMs  to  alleviate  energy 
poverty’598. 

Other stakeholders advocated for an increased focus on energy security and sustainable 
development599  or  a  rethinking  of  industrial  strategy  and  social  policies600.  Stakeholders 
also suggested that NECPs should better connect with economic governance601. According 
to experts from the European Commission, this disconnection is exacerbated by the lack 
of robust macroeconomic assessments of the PaMs included in the NECPs, despite being a 
requirement under the Governance Regulation and despite the macroeconomic relevance 
of  the  transition  to  climate  neutrality  and  its  impact  on  public  finance602.  Stakeholders 
suggested  that  NECPs  should  include  (more)  economic  constraints  relating  to  lowering 
dependence on fossil fuels, as well as a binding path towards a carbon negative economy 
within planetary boundaries603.  

According  to  two  stakeholders,  the  issue  of  skills  and  labour  shortages  in  particular 
segments of the labour market (e.g. installers of heat pumps) play a critical technological 
role  in  facilitating  clean  energy  transition,  but  is  not  well  reflected  in  the  Governance 
Regulation604. They explained that supply in the labour market does not seem to follow the 
demand for these skills and the relevance of the Governance Regulation could be increased 
here. Indeed, a 2023 policy brief from the JRC found that job vacancy rates had increased 

plans, 

2022/C 

495/02, 

596 Replies to CfE: CAN Europe, Transport and Environment, WWF Europe, Ministry of Climate and Environment 
of Poland, the Sustainability of the Earth System, European citizen (Spain), Baltic environmental organisations. 
597 Commission Notice on the Guidance to Member States for the update of the 2021-2030 national energy and 
climate 
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52022XC1229(02)    
598 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions, 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,  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2023%3A796%3AFIN&pk_campaign=preparatory&pk_source=EURLEX&pk_medi
um=TW&pk_keyword=EUGreenDeal&pk_content=Communication&pk_cid=EURLEX_todaysOJ 
599 Reply to CfE: Ministry of Climate and Environment of Poland. 
600 Reply to CfE: Transport and Environment. 
601 Scoping interview with an EU agency. 
602 Submission by EU Commission. 
603 Reply to CfE: Germanwatch e V.  
604 Interviews with EU institution (1) and industry association (1). 

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in  almost  all  Member  States  in  sectors  relevant  to  the  energy  transition,  such  as 
manufacturing, energy supply, construction and in scientific and technical activities, with 
an ageing workforce in some of these sectors605. 

One practice that could encapsulate particular risks or challenges is the modelling of the 
circular  economy  within  the  NECP  framework,  as  exemplified  by  the  Portuguese  Draft 
Updated  NECP606  and  the  Dutch  Modelling  and  Steering  Circular  Economy  Work 
Programme607. The current Regulation provides the flexibility for countries to trial such an 
approach,  but  could  perhaps  scale-up  or  encourage  such  initiatives  if  they  prove  an 
effective means of mitigating risks at a macroeconomic level.  

6 

CONCLUSIONS AND LESSONS  

This section presents the conclusions of the evaluation, based on the findings outlined in 
Section 5. They are presented per evaluation criteria.  

6.1  Effectiveness 

The  evaluation  finds  that  the  Governance  Regulation  has  improved  the  quality  of  the 
reported information and planning across the Energy Union’s five dimensions, notably in 
the NECPs and LTSs. However, significant variations exist in the Regulation’s effectiveness, 
depending on how it is implemented by each Member State. Stakeholders’ views differed 
on  whether  the  provisions  of  the  Governance  Regulation  are  sufficiently  prescriptive  or 
whether they should retain flexibility to account for national variations.  

6.1.1  Quality of information 

The  evaluation  finds  that  while  the  Governance  Regulation  has  enhanced  the  quality  of 
information reported in the NECPs, some issues persist with the completeness of reported 
data.  There  are  indications  that  individual  Member  States  have  taken  divergent 
approaches, potentially influencing the nature of the information collected.  

The  evaluation  finds  that  the  Governance  Regulation  has  effectively  contributed  to 
improved accuracy in the data on the five dimensions to be covered in the LTSs (Article 
15(4)).  However,  divergent  national  planning  traditions  negatively  impacted  the 
completeness of the LTSs, with Member States not always reporting all mandatory content, 
or doing so not coherently with their NECPs.  

On the quality of the information reported in the NECPRs and their follow up, the evaluation 
finds that the enforcement of Articles 17-25 has proved effective only to some extent, with 
significant data gaps remaining. On the integrated planning and reporting on GHG PaMs 
and  projections  (Article  18),  the  evaluation  finds  that  while  the  number  of  PaMs  has 
increased  over  time,  the  completeness  of  reported  information  (particularly  quantitative 
information) has not improved substantially. The quality of information on projections of 
anthropogenic GHG emissions by sources and removals by sinks increased between 2017 
and 2021.  

6.1.2  Timeliness of information  

The  evaluation  finds  that  the  timely  submission  of  draft  NECPs  was  not  consistently 
achieved. It is unclear whether this problem is directly linked to the Governance Regulation 
or whether it results from practices and/or procedural bottlenecks at Member State level.  

605 European Commission, Science for Policy Brief - Skills for the energy transition in the changing labour market, 
JRC135382, 2023. 
606 ‘As in the past, an assessment of the potential effects of circular strategies, e.g. on energy consumption, waste 
generation  and  carbon  retention,  will  be  carried  out  with  the  identification  of  the  (sectoral)  impact  emission 
modelling variables’ (Portuguese Draft Updated NECP, p. 206). 
607 
https://www.pbl.nl/uploads/default/downloads/pbl-2023-werkprogramma-monitoring-en-sturing-ce-5190.pdf  

Leefomgeving,  Werkprogramma  Monitoring 

Planbureau 

Sturing, 

2023, 

voor 

de 

& 

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The evidence showed significant delays in the submission of LTSs, with subsequent delays 
and  inefficiencies  in  the  Commission’s  EU-wide  assessment  of  the  LTSs.  There  are 
indications  that  the  lack  of  timeliness  in  the  submission  of  LTSs  derives  from  both 
insufficient  national  administrative  capacity  to  fulfil  the  reporting  obligations  under  the 
Governance Regulation and the sequencing of the planning and reporting obligations (e.g. 
NECP deadline prior to LTS deadline). There is no evidence that the Governance Regulation 
itself  was  ineffective  in  ensuring  that  LTSs  were  submitted  in  a  timely  manner;  rather, 
enforcement and administrative burdens seem to have caused the delayed submission of 
LTSs.  

The  evaluation  finds  that  the  NECPRs  and  reporting  obligations  (Article  17  of  the 
Governance Regulation) were submitted on time or with a small delay that did not impact 
the effectiveness of the Governance Regulation.  

The timeliness of information on PaMs remained stable between 2017 and 2019, improved 
in  2021,  then  deteriorated  in  2023.  Information  reported  on  the  projections  of 
anthropogenic  GHG  emissions  by  sources  and  removals  by  sinks  improved  in  2019 
compared to 2017, but also deteriorated in 2021. The evaluation does not find a lack of 
effectiveness that can be attributed to the Governance Regulation.  

6.1.3  (Public) accessibility of information  

The  Governance  Regulation  facilitated  greater  access  to  certain  information  for  all 
stakeholders, including policymakers, investors, and the general public, compared to the 
baseline situation. However, stakeholders held divergent views on whether the Governance 
Regulation has contributed to better quality or  relevance of that information. It remains 
unclear whether this issue is linked to the Governance Regulation itself, its implementation 
by the Member States, and/or different national traditions across the EU.  

6.1.4  Planning processes and implementation of plans and reports 

The Governance Regulation has been effective in promoting better planning processes. For 
instance,  it  has  helped  to  streamline  planning  processes  across  the  energy  and  climate 
domains,  with  increased  cooperation  between  ministries/authorities  at  national  level. 
Nevertheless, in several Member States, NECPs are not particularly relevant for national 
planning processes and are mainly developed to meet the EU obligation. Similarly, LTSs 
are  partly  outdated  and  do  not  necessarily  serve  as  the  basis  for  NECP  development.  
Stakeholders underlined the lack of attention paid to LTSs, including the absence of a close 
monitoring process after their adoption. National authorities agreed that the Governance 
Regulation played a role in influencing Member States to adopt or implement PaMs to meet 
national energy and climate contributions.  

6.1.5  Enforcement  

Evidence shows that the main obstacle to implementation is the fact that the enforcement 
mechanism is mainly based on recommendations, which are not legally binding.  

6.1.6  Regional cooperation 

Regional  cooperation  has  been  somewhat  stimulated  by  the  Governance  Regulation. 
Although Member States have engaged in regional cooperation through various forums and 
initiatives  on  different  dimensions  of  the  Energy  Union,  the  potential  of  regional 
cooperation has yet to be fully exploited. For example, both the 2019 EU-wide assessment 
of the draft NECPs and the 2020 EU-wide assessment of the final NECPs indicated the need 
to enhance regional cooperation efforts. Ongoing challenges include the limited time given 
to  Member  States  to  consult  on  each  other’s  NECPs  and  the  lack  of  comparable  data 
between Member States.  

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6.1.7  Stimulating spending and investment  

Limited  evidence  is  available  on  the  extent  to  which  the  Governance  Regulation  has 
stimulated targeted spending and investment and/or enhanced predictability for investors. 
The European Commission’s assessments revealed that NECPs lack detail on investment 
needs and funding sources – this was confirmed by the industry representatives consulted. 
Stakeholders  also  lacked  awareness  of  the  situation  before  the  Governance  Regulation 
entered  into  force  and  were  unable  to  attribute  spending  and  investment  trends  to  the 
Regulation. 

6.1.8  Ensuring  adequate  multi-level  and  multi-stakeholder  dialogue  and 

consultation 

Although the introduction of Articles 10 and 11 of the Governance Regulation are perceived 
as  a  significant  step  forward,  the  Governance  Regulation  has  not  been  particularly 
successful  in  ensuring  adequate  multi-level  and  multi-stakeholder  dialogue  and 
consultation. Several Member States have failed to establish public consultation or multi-
level and multi-stakeholder dialogue of an acceptable quality. 

6.2  Efficiency 

The efficiency analysis shows mixed results. The Governance Regulation has streamlined 
some aspects of energy policy planning and reporting, and some national authorities were 
able to point to areas where the Regulation saves time and/or resources. Others, however, 
noted that the Governance Regulation has increased administrative burdens. Stakeholders 
acknowledged that some costs were linked to the initial learning curve, with reporting and 
planning processes expected to become simpler and less burdensome over time. It is also 
difficult to separate the workload created by the Governance Regulation from the workload 
generated by organisational aspects of the national administrations.  

Recognised  benefits  of  the  Governance  Regulation  include  increased  transparency  and 
predictability, better cross-border coordination and cooperation among national authorities 
involved  in  the  reporting  process,  higher  coherence  of  planning  and  reporting  timelines 
and procedures, and better-established processes, policies, and procedures. The benefits 
of  the  Governance  Regulation  also  include  its  provision  of  a  stable  framework  for  clean 
energy  businesses,  which  is  crucial  for  long-term  investment  and  development  in  the 
sector.  

The Regulation has partially streamlined planning, reporting and monitoring processes, but 
falls short of achieving complete harmonisation and full alignment with the timing of other 
EU and international obligations (e.g. biennial reporting for the UNFCCC in even years, and 
NECPRs in odd years). The alignment of timetables for various tasks (e.g. preparing NECPs 
and NECPRs in close succession) has resulted in a lack of adequate incorporation of lessons 
from previous planning cycles, as well as overlapping NECP updates and NECPRs in 2023.  

The Governance Regulation introduced common templates for the NECPs and NECPRs and 
introduced  (ReportENER)  or  strengthened  (Reportnet)  the  use  of  digital  platforms. 
Stakeholders  had  mixed  views  on  the  time  and/or  resource  savings  of  these  common 
templates and platforms. They referred to the need to reformulate data and information 
before  uploading,  generating  cost  increases,  and  emphasised  the  lack  of  a  tool  for 
compiling  and  sharing  comprehensive  answers  from  different  contributing  authorities 
within  each  reporting  country.  They  also  mentioned  the  lack  of  linkages  between  the 
platforms. However, some cost/burden reductions have been achieved. For instance, the 
platforms provide additional clarity about the information and data that should be collected 
and submitted, remove the need for Member States to develop their own national tools, 
and enable several users to access information simultaneously. Some stakeholders noted 
that  the  two  platforms  play  a  role  in  standardising  reporting  and  systematising  data 
information. 
collection,  thereby 
Nevertheless,  the  existence  of  two  separate  platforms  (ReportENER  and  Reportnet) 

facilitating  the  availability  and  comparability  of 

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garnered  some  criticism  from  stakeholders,  particularly  the  inadequate  connections 
between the two platforms, and differences in formats.   

6.3  Coherence 

Overall,  evidence  showed  that  the  Governance  Regulation  has  streamlined  previously 
existing planning and reporting obligations from various pieces of legislation across energy, 
climate, and other Energy Union-related policy areas. However, some inconsistencies affect 
both the internal and external coherence of the Governance Regulation. 

Internal coherence issues generally reflect the complexity of integrating many obligations 
into  a  single  framework  and  the  many  changes  occurred  since  the  adoption  of  the 
Governance Regulation in December 2018. There is some evidence of a lack of coherence 
between  the  reporting  obligations  under  the  Governance  Regulation,  notably  between 
NECPs and LTSs, in relation both to the process and the timeline. 

External coherence issues generally reflect the fact that several EU-level instruments have 
been introduced and/or updated since 2018, notably the various policies developed under 
the European Green Deal, as well as different reporting timelines compared to the UNFCCC 
reporting  cycle.  The  timing  of  different  reporting/planning  obligations  are  not  always 
aligned. For instance, the recast EED includes many new elements for stronger governance 
that are neither incorporated nor streamlined into the Governance Regulation. Similarly, 
the  revised  RED  introduced  new  elements  that  are  not  reflected  in  the  Governance 
Regulation.  

6.4  EU added value 

The EU added value of the Governance Regulation stems from a notable improvement in 
consistency  in  national  energy  and  climate  policies.  This  impact  varied  across  Member 
States and depended on the national processes that preceded the Governance Regulation.  

Stakeholders  agreed  that  the  Governance  Regulation  has  contributed  to  enhanced 
coordination  in  national  energy  and  climate  policies.  They  noted,  however,  that 
coordination with sub-national actors could be strengthened.  

The  planning  and  reporting  obligations  set  out  in  the  Governance  Regulation  provide 
additional information at EU and national level. The Regulation has increased information 
availability  by  publishing  reports  and  data  for  Member  States  which  might  not  do  so 
themselves,  and  requesting  data  on  indicators  that  certain  Member  States  may  not 
previously  have  collected  or  reported.  Stakeholders  highlighted  the  added  value  of 
information from other  Member States, both being able to access other Member States’ 
plans  and  through  the  Commission’s  assessment  and  reporting.  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. 

While  the  Governance  Regulation  had  a  positive  effect  on  the  reporting,  availability  and 
predictability  of  data,  stakeholders  highlighted  issues  with  timely  submission,  quality 
(completeness), accessibility and transparency of data.  

There were contrasting views on the added value of the Governance Regulation in ensuring 
accountability  and  access  to  justice.  Some  stakeholders  (often  national  authorities) 
highlighted that it has enabled better accountability and access to justice across a number 
of  key  domains  by  introducing  data  reporting  requirements  and  mechanisms  to  enforce 
standards.  Third  sector  respondents,  however,  pointed  to  the  lack  of  significant 
improvements in accountability and access to justice. They did not fully believe that the 
Governance Regulation provides adequate mechanisms to hold Member States and the EU 
accountable  for  their  obligations  under  the  Regulation,  and  a  majority  stated  that  the 
Governance  Regulation  does  not  support  access  to  justice  for  public  and  private 
stakeholders.  The  difference  in  these  perspectives  may  reflect  differences  in  national 

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legislation (creating different routes to accountability mechanisms), as well as differences 
in implementation and adherence to the Governance Regulation. 

6.5  Relevance 

The  evaluation  found  that  Governance  Regulation's  core  objective  of  providing  a 
governance  structure  that  enables  and  pushes  Member  States  to  commit  and  deliver 
ambitious climate targets has not lost its relevance. Rather, 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 Governance Regulation – to enable and support climate action – is 
more relevant than ever.  

Since the adoption of the Governance Regulation in 2018, the EU energy and climate acquis 
has  undergone  important  developments,  notably  the  Fit  for  55  package.  As  a  primarily 
procedural  framework  that  does  not  itself  set  specific  targets,  the  relevance  of  the 
Governance  Regulation  is  somewhat  safeguarded.  However,  certain  issues  reflected  in 
recent legislation need to be better addressed both in the framework and in the products 
adopted under the Regulation, such as the NECPs. 

The  governance  mechanisms  of  the  Regulation  do  not  adequately  address  some  of  the 
issues now at the forefront of energy policy due to more recent geopolitical and legislative 
developments.  Themes  that  do  not  appear  to  be  adequately  reflected  include  a  broader 
understanding of energy security and the need for a resilient and competitive clean energy 
industry. This may negatively impact the ability of the Governance Regulation framework 
to fully respond to emerging needs in European energy and climate policy. Russia’s war of 
aggression against Ukraine disrupted EU energy policy across several dimensions. While 
lending additional relevance to the Energy Union’s objectives and accelerating clean energy 
transition, it also prompted a recalibration of immediate policy priorities and highlighted 
transition challenges. 

The  energy  supply  crisis  following  Russia’s  war  of  aggression  against  Ukraine  and  the 
COVID-19 pandemic highlighted social and economic challenges that need to be addressed 
if climate change and just transition goals are to be met in the long term. Feedback from 
stakeholders  suggested  that  socioeconomic  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.  

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ANNEX 1. METHODOLOGICAL APPROACH AND LIMITATIONS 

This  annex  explains  the  approach  to  the  data  collection,  limitations  in  the  sources  and 
methods used and the mitigation measures that have been applied.  

A1.1. Desk research  

The research team has conducted a comprehensive review of relevant secondary literature, 
information  and  data.  The  information  derived  through  desk  research  has  been  used  to 
answer  the  evaluation  questions  but  also  to  contextualise  and  validate  the  information 
derived  through  the  consultation.  Relevant  literature  and  data  have  been  drawn  from  a 
variety of sources including the European Commission, the Member States, peer-reviewed 
publications,  and  directly  from  stakeholders  (including  third  sector  organisations  and 
industry) as part of the consultation. Although relevant literature and data were primarily 
identified through searches conducted in English, the research team also conducted some 
targeted searches in other EU languages to fill known information gaps and for the country 
case  studies.  It  is  nevertheless  possible  that  some  relevant  information  unavailable  in 
English may have been missed. The desk research also focused primarily on literature and 
data published in the years immediately leading up to the Governance Regulation (2015-
2018) and since the Governance Regulation was adopted (2018-2023). Literature and data 
published after the end of January 2024 has not been included.   

Information from the various literature and data sources has been extracted and coded for 
its relevance to the specific research questions and triangulated across sources and with 
the  primary  information  collected  through  the  consultation.  The  research  team  also 
undertook a comprehensive review of literature focusing on the costs and benefits of the 
Governance Regulation to inform the baseline and efficiency analysis. A key source in this 
respect has been the fitness check conducted in 2016 on the EU energy acquis (SWD(2016) 
396 final).  

A1.2. Call for evidence  

Between 6 July 2023 and 3 August 2023, DG ENER and DG CLIMA ran a call for evidence 
on  the  'Have  your  say'  portal.  The  objective  of  the  call  for  evidence  was  to  provide 
stakeholders and the public with an opportunity to share their views on the functioning of 
the  Governance  Regulation.  The  target  audience  of  the  call  for  evidence  included 
organisations, social partners, the scientific community, and the general public, Member 
State authorities, and other public authorities.     

A  total  of  53  respondents,  covering  eight  respondent  groups,  replied  to  the  call  for 
evidence.  The  majority  of  respondents  were  Non-Governmental  Organisations  (NGOs) 
(34%, 18), 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 academics or research institutions (6%, 3). 

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Figure 52. Overview of respondents by respondent group (n=23) 

Source: ICF elaboration 608  

A  total  of  16  EU  Member  States,  and  two  third  countries  (the  United  Kingdom  and 
Australia) were represented in the responses. The most represented country was Belgium 
(35%, 18), followed by Germany (17%, 9), and Spain (8%, 4). It should be noted that 
respondents  from  Belgium  generally  comprised  NGOs,  business  associations  or 
environmental  organisations  representing  a  wider  variety  of  actors  from  across  the  EU 
(such  as  the  WWF  European  Policy  Office,  Eurocities,  SolarPower  Europe,  European 
Geothermal Energy Council, and the European Network for Community-led initiatives on 
climate change and sustainability) (see Figure A1.1Figure 53. below).  

Figure 53. Overview of responses by country (n=53) 

Source: ICF elaboration  

Most stakeholders provided a position paper of three to four pages, or less structured views 
on the Governance Regulation or on the Climate and Energy Framework overall.  

608 Please note that one EU citizen (from FI) submitted five responses on the portal. To prevent double counting, 
only one reply was counted (incorporating the views from the different submissions). Also note that three replies 
(from IE, DK, and LV) were provided by DG ENER and were not submitted to the Have your Say portal.  

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To  analyse  the  feedback  submitted  by  stakeholders,  the  ICF  team  developed  an  Excel 
matrix through which we mapped the inputs provided by stakeholders. More specifically:  
  Information was mapped according to evaluation criteria and evaluation questions.  
  The  matrix  included  columns  dedicated  to  the  identified  issues  (which  will  inform 
the problem definition), and suggested approaches (to inform the development of 
the policy options). Stakeholder feedback was further organised by thematic area 
(e.g., views on NECPs, LTs, Enforcement, Timing, Public Consultation), to facilitate 
the  correlation  between  the  problem  identified  and  the  suggested  policy 
options/solutions.  

Overall, respondent groups and the geographical distribution of respondents to the call for 
evidence were well-balanced, but the response rate was relatively low. 

The ICF team presented an overview of the feedback provided through the call for evidence 
at the meeting with the ISG on 5 September 2023.  

A1.3. A1.4 Targeted surveys 

We  used  a  set  of  targeted  surveys  to  gather  information  from  the  three  following 
stakeholder  groups:  national  authorities,  industry  organisations  and  third-sector 
stakeholders. Surveys were designed per stakeholder groups and targeted at the contacts 
selected  for  the  Study,  most  of  whom  were  also  invited  to  participate  in  more  in-depth 
semi-structured online interviews. 

The purpose of the surveys and steps taken for the launch of the first round 

The  first  round  of  targeted  surveys  was  launched  on  4  October  2023  and  closed  on  27 
November 2023.  

The  surveys  covered  questions  of  relevance  to  the  evaluation,  as  well  as  some  scoping 
questions  to  inform  the  problem  definition.  As  agreed  with  the  Commission  during  the 
inception  phase,  the  surveys  excluded  questions  about  potential  policy  options  though 
participants  were  able  to  provide  additional  comments  and  had  the  possibility  to  attach 
documents.  

After proceeding with a cleaning of the data to remove unusable contributions, the surveys 
were  found  to  have  gathered  a  total  of  70  responses.  This  included  33  responses  from 
national authorities, 20 responses from third-sector stakeholders and 17 responses from 
industry organisations. 

A1.3.1. A1.4.1 The survey design 

Three separate surveys were created and disseminated in a tailored fashion as part of the 
Evaluation. The surveys were designed with the Commission’s feedback and approval, with 
questions developed based on the Evaluation Framework agreed between ICF, DG ENER, 
and DG CLIMA on 25 July 2023 (see Table 37 in Annex 4). Three surveys were disseminated 
to the following stakeholder groups: 

  Survey  to  national  authorities.  This  survey  covered  the  questionnaires  for 
national authorities competent for the Governance Regulation and for other national 
authorities,  agencies  and  bodies.609  The  rationale  behind  combining  these  two 
questionnaires was that many questions were  common to all national authorities, 
although  the  survey  still  included  very  specific  branching  depending  on  the  tasks 
and specialisation of the responding authority.  

  Survey  to  industry  stakeholders.  This  survey  covered  questionnaires  for  the 
energy industry and  for energy intensive industries (respectively the  ‘supply’ and 

609 These were listed as Questionnaire #3 and #4 in our Inception Report. 

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‘demand’ counterparts of the energy sector).610 The definition for energy intensive 
industries  was  taken  from  the  European  Commission’s  website;  we  have  also 
included  the  automotive  and  land  sector  in  our  consultations.  The  created 
questionnaire  included  questions  specific  to  energy  producers  and  consumers, 
notably in  cases where  organisations  specified  that they played a role in national 
data collection and reporting. 

  Survey  to  third-sector  stakeholders.  This  survey  contained  questions  for 
stakeholders  such  as  civil  society  (including  consumer  organisations),  NGOs, 
professional  unions,  research  organisations  and  think  tanks,  as  well  as  academic 
experts.  

A1.3.2. A1.4.2 Survey distribution 

The surveys were ‘live’ for approximately eight weeks between 4 October and 27 November 
2023.  During  this  time,  the  surveys  were  sent  to  657  individual  contacts,  including  219 
contacts at national authorities, 289 industry contacts and 146 third-sector stakeholders, 
representing  around  85  different  national  authorities,  around  210  different  industry 
organisations and around 115 different third-sector organisations (not counting individual 
experts). Relevant contacts, including organisations, named individuals and contact email 
addresses were identified through desk research conducted in multiple EU languages and 
by recommendation from the Commission.  

The  surveys  were  initially  sent  to  482  contacts  on  4  October  2023.  However,  by  late 
October, it was becoming clear that the response rate was going to be quite low. To boost 
the response rate, a further 175 contacts were identified and contacted during late October 
and mid-November, bringing the total contacts to 657. Between one and three reminders 
were  also  sent  to  stakeholders,  depending  on  our  first  date  of  contact  with  each 
stakeholder. 

Invitations to participate in the consultation, and the questionnaires, were tailored for each 
stakeholder group. The invitations included a request to complete the survey, an invitation 
to participate in an interview and (where applicable) a request to distribute the survey to 
other  relevant  parties  (e.g.,  membership  of  the  organisation  being  contacted).  The 
invitation included a PDF copy of the Commission’s accreditation letter. Participation in the 
survey  and  interview  included  the  respondent’s  express  consent  to  ICF’s  privacy  policy, 
which  clearly  explained  the  terms  under  which  (personal)  data  were  collected  and  have 
been used. 

Responses to the  email and any follow-ups were managed through a  dedicated mailbox 
and responses were closely monitored and tracked.  

A1.3.3. A1.4.3 Survey analysis 

Replies  submitted  to  the  surveys  were  cleaned  and  analysed  over  the  week  and  a  half 
following the established deadline of 27 November 2023. 

The box below explains the data quality and data cleaning process we followed to ensure 
we had usable data for reporting. 

A1.3.4. A1.4.4 Data quality and data cleaning process 

The threshold established to retain survey answers was a 50% response rate to questions 
presented to respondents. Submitted or non-submitted answers below that threshold were 
discarded due to their evident incompleteness – in practice, this affected survey responses 
where participants had only answered one or two questions. Duplicate responses were also 
discarded based on answers provided and on the IP address of the respondent. There were 

610 These were listed as Questionnaires #1 and #2 in our Inception Report. 

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no  two  answers  passing  the  50%  response  rate  threshold  and  sharing  identical  replies  – 
however,  several  incomplete  responses  appeared  to  have  been  submitted  by  the  same 
respondents or to be duplicates of a more substantial response. This especially affected the 
survey to national authorities, where it seemed that such responses had been used to flick 
through  and  test  the  survey  first.  Such  duplicates  were  systematically  discarded  and 
responses passing the 50% completeness test were kept when available instead.  

Given the timeline of our stakeholder consultations (as well as the specificity of the topic), 
we did not require national authorities to submit consolidated responses representing the 
official stance of their Member State on the Governance Regulation. As such, we analysed 
responses by national authorities based on the authority, agency or service these responses 
came  from  (which  respondents  were  mandated  to  identify).  In  certain  cases,  several 
responses  were  submitted  from  authorities  in  the  same  Member  State,  or,  more  rarely, 
belonging  to  the  same  authority  (for  example,  answers  from  different  services  within  a 
national  ministry).  For  all  such  answers  passing  our  50%  completeness  threshold,  it  was 
clear  that  the  answers  were  not  identical,  had  been  submitted  by  different  authorities  or 
services,  and  sometimes  related  to  different  aspects  of  the  Regulation  (e.g.,  focusing  on 
different reporting obligations). These answers were saved and used in the present report 
in a way that differentiates between different responses in a given Member State and clarifies 
instances  where  a  respondent’s  contribution  only  pertained  to  a  limited  aspect  of  the 
Regulation. 

There were no instances of duplicates passing the 50% completeness threshold or that any 
responses appeared to  have submitted as part of an organised campaign across all three 
surveys.  

Following  data  cleaning,  quantitative  survey  replies  were  analysed  using  Excel.  Analysis 
was  conducted  per  survey  (i.e.,  per  stakeholder  group)  and  per  evaluation  questions 
(where  possible,  across  two  or  all  three  stakeholder  groups).  Given  the  manageable 
number  of  final  replies  recorded  (70),  analysis  of  open-ended  question  was  conducted 
manually  by  individual  report  drafters  as  part  of  the  evidence  review  per  evaluation 
questions.  

A1.4. Interviews  

Ten scoping interviews and thirty-five key informant interviews (KIIs) were conducted as 
part of the evaluation, and a further 35 targeted interviews have been conducted as the 
basis for the (Table 28A1.1).  

Table 28.  Number of key informant interviews conducted 

Stakeholder group 

Scoping 
interviews 
conducted 
Evaluation  
(Task 0.3) 

- 

Key 
interviews 
conducted 
Evaluation 
(Task 1) 

- 

Case 
interviews 
conducted 
Evaluation 
(Task  

informant 

study 

–

European Commission and other EU entities 4 

Member State competent authorities for the 
Governance Regulation 

4 

Other  Member  State  authorities,  agencies 
and bodies 

0 

4 

4611 

2 

0 

21 

0 

611 Due to several Member States opting to conduct combined interviews, it should be noted that our interviews 
with national authorities eventually involved 11 separate national ministries and agencies. 

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Stakeholder group 

Scoping 
interviews 
conducted 
Evaluation  
(Task 0.3) 

- 

Key 
interviews 
conducted 
Evaluation 
(Task 1) 

- 

Case 
interviews 
conducted 
Evaluation 
(Task  

informant 

study 

–

International organisations 

0 

EU industry associations and organisations  0 

EU NGOs and civil society organisations 

Other (e.g., academia, think-tanks) 

Total 

1 

1 

10 

0 

6 

19 

3 

35 

0 

2 

12 

0 

35 

A1.4.1. A1.5.1 Interview design, methodology and analysis 

The  topic  guides  used  for  the  interviews  were  based  on  the  Evaluation  Questions  (EQs) 
contained in the Evaluation Framework, as agreed with DG ENER and DG CLIMA on 25 July 
2023  (see  Table  37  in  Annex  4).  Specific  topic  guides  were  designed  for  national 
authorities, industry organisations, third-sector stakeholders, European entities as well as 
intergovernmental organisations.  

Interviews  were  conducted  via  Microsoft  Teams  and,  where  consent  was  given  by  the 
interviewee, were recorded and/or transcribed. Interviewers also took written notes, which 
were used as the main basis for the analysis. These interview notes were extracted, coded 
per evaluation criterion and evaluation question and analysed using NVivo and Microsoft 
Excel.  

A1.4.2. A1.5.2 Interview distribution 

Interview invitations were sent to 699 individual contacts. These comprised 219 contacts 
for  national  authorities,  299  industry  contacts  and  160  third-sector  stakeholders, 
representing  around  85  different  national  authorities,  around  210  different  industry 
organisations and around 115 different third-sector organisations (not counting individual 
experts). Contacts were identified through desk research and recommendations made by 
the European Commission. Most interview invitations sent to national authorities, industry 
organisations and third-sector stakeholders offered the possibility to complete the online 
targeted surveys. Contacts were also invited to forward the email to their members (where 
applicable)  or  other  relevant  stakeholders.  The  invitation  included  a  PDF  copy  of  the 
Commission’s  accreditation  letter  as  well  as  topic  guides  providing  an  indicative  list  of 
interview questions per stakeholder type. Interviews were booked through Bookings™, on 
which  recipients  of  the  invitation  could  book  interviews  directly  in  the  calendars  of  the 
team. 

ICF first sent interview invitations to 484 contacts on 4 October 2023, as well as reminders 
and follow-ups until 7 November 2023. During this time, it became increasingly clear to 
the  study  team  that  the  response  rate  would  be  lower  than  hoped,  and  so  additional 
contacts  were  identified  and  emailed  in  the  hope  of  boosting  the  interview  participation 
rate. Some contacts within EU industry associations were also approached via LinkedIn, 
where an email address was not publicly available.  

Despite the various mitigating measures taken to try and boost the participation rate for 
interviews, the team did not manage to conduct the 60 interviews initially hoped for during 
the evaluation. Consequently, the answers to the evaluation questions are based on less 

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first-hand  information  and  narrower  feedback  than  initially  envisaged,  which  may  have 
prevented or hindered robust conclusions from being drawn. 

A1.5. A1.6 Stakeholder event 

A stakeholder event was organised by DG ENER and DG CLIMA on 11 January 11 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 (including answers to the SLIDO polls asked to participants during the event) 
have been integrated into the findings presented in the remaining sections of this report.  

A1.6. A1.7 Case studies  

During  the  evaluation,  seven  country-focussed  case  studies  have  been  conducted  to 
explore, in-depth, the procedures and processes in place 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 explore three main 
thematic  topics:  i)  public  consultation  and  multilevel  climate  and  energy  dialogues,  ii) 
regional cooperation, and iii) compliance.  

The  seven  Member  States  selected  as  case  studies,  in  collaboration  with  the  European 
Commission were 612:  Belgium, Denmark, France, Germany, Malta, Romania, and Poland. 
This selection of countries ensures representativeness, in terms of:  

  geographical coverage and country size; 
  diversity  of  institutional  systems  (with  some  Member  States  having  a  federal 
system, unlike others), and countries where reporting responsibilities are organised 
differently (i.e., combined within the same ministry or spread across ministries); 
  performance  on  environmental  and  climate  targets  (measured  by  levels  of  GHG 

 

emissions; 
their  NECPs,  with  some  receiving  positive  assessments  and  others  having  gaps 
identified within them; and,  

  having or not having submitted a national Long-Term Strategy (LTS). 

Table 29A1.2 below provides an overview of the thematic scope of the case studies for the 
evaluation.  

Table 29.  Thematic scope of the case studies for the evaluation 

Topics 
covered 

to 

be 

Relevant 
provision(s) 
of 
Governance 
Regulation 

the 

Background 
section 

  N/A 

Areas of interest 

 

 

to 

institutional  systems  of  the  country  (i.e. 
how  the  reporting  responsibilities  are 
the  different  national 
attributed 
authorities  –  e.g.  combined  within  the 
same  ministry 
across 
or 
ministries),  
the  compliance  with  the  Governance 
Regulation so far (e.g. submission of their 
national LTS, their NECPs, etc.) 

spread 

612 The final list of Member States covered by the case studies was agreed with DG ENER and DG CLIMA on 8 
November 2023 

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Topics 
covered 

to 

be 

Relevant 
provision(s) 
of 
Governance 
Regulation 

the 

Areas of interest 

Costs  and  benefits 
of 
the  planning, 
reporting, 
monitoring 
and 
other  obligations 
of  the  Governance 
Regulation 
for 
different 
categories 
stakeholder 

of 

Public consultation 
Multilevel 
and 
Climate and Energy 
Dialogues (MCEDs) 

  All  reporting 
obligations  

  Article 10 

  Article 11 

Regional 
cooperation 

  Article 2(21) 

  Article 12 

  Article 22  

  Annex 1 

Compliance 

  Article 31 

  Article 32 

  Quality of the reporting (e.g. assessments 

of their NECPRs) 

  Performance  on  key  environment  and 
climate indicators (e.g. GHG emissions) 

  Costs  (administrative  burdens)  for  public 
authorities, industry, and other categories 
of stakeholder 

  Benefits of the Governance Regulation for 
public  authorities,  industry,  and  other 
categories of stakeholder 

  Extent  to  which  the  scope  of  article  10  is 
sufficient,  suitable  and  efficient  (also  in 
relation  to  the  interaction  with  the  SEA 
Directive 2001/42/EC and with the Aarhus 
Convention) 

  Extent  to  which  the  scope  of  article  11  is 

sufficient, suitable, and efficient  

  How/whether  regional  cooperation  has 
contributed to fulfilling the obligations with 
respect to: 

-  Security of supply dimension, and 
-  Climate 

and 
adaptation  (e.g.,  regional  water  and 
forest management) 

change  mitigation 

  Delivery  of  NECPs/NECPRs  (explore  root 
causes  of  potential  delays  and  quality 
issues) 

  National  follow-up  of  the  NECPs  and  LTS 
in 
measures  (monitoring  of  progress 
Member States across departments/bodies 
–  how 
to  Member  States  ensure 
implementation/compliance,  including  of 
national  Energy  Efficiency/Renewable 
Energy/Climate  targets  of  the  different 
administrative levels – local/regional) 

  Explore  whether 

filling 
mechanism,  as  well  as  the  Commission's 
recommendations  on  NECPs  and  NECPR, 

gap 

the 

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Topics 
covered 

to 

be 

Relevant 
provision(s) 
of 
Governance 
Regulation 

the 

Areas of interest 

plays  a  role  in  how  the  delivery  and 
national  follow-up  are  implemented  .  On 
that basis, explore whether the gap filling 
architecture  is  fit  for  purpose  or  whether 
the  relevant  provisions  need  to  have  a 
larger scope (e.g., security of supply).   

Source: ICF elaboration 

The  case  studies  draw  on  information  gathered  through  desk  research  and  stakeholder 
consultation,  including  relevant  information  from  the  general  programme  of  stakeholder 
consultation (including the call for evidence, surveys, and interviews described above) for 
the evaluation, as well as more targeted desk research and stakeholder interviews in the 
seven case study Member States, conducted between November 2023 and February 2024.   

As regards desk research, national researchers have reviewed evidence provided by the 
European  Commission  (e.g.,  NECP,  LTS,  NECPRs  progress  report,  EC  assessments)  and 
additional  sources  at  the  EU,  national  and  local  level  (e.g.,  key  national  strategies  or 
planning documents). 

National  researchers  have  also  conducted  interviews  with  relevant  stakeholders  in 
each of the seven case study countries, including (where possible):  

  Lead national body tasked with the overall coordination and monitoring of the NECP; 
  Other  national  administrations  and  authorities,  line  ministries  involved  in 

implementation/ reporting; 
  Regional or local authorities; 
  Social  partners,  business  associations,  civil  society,  think  tanks/academics  and 

journalists following the topics. 

The consultants collaborated with DG ENER and DG CLIMA to identify contacts for the case 
study interviews and identified contacts by drawing on the stakeholders mapping carried 
out during the study inception phase and following-up with contacts that had participated 
in the earlier rounds of consultation, including the stakeholder event held on 11 January 
2024. Nevertheless, the process of contacting national stakeholders and scheduling case 
study  interviews  was  longer  and  more  challenging  than  expected.  Many  reminders  and 
additional  contacts  proved  necessary,  and  the  level  of  interest  from  stakeholders  other 
than  national  authorities  was  very  limited.  Consequently,  the  case  studies  lack  the 
anticipated  level  of  detail,  drawing  from  a  narrower  scope  and  depth  of  stakeholder 
perspectives.  This presents a  significant limitation, particularly as the efficiency analysis 
hinges on the quality of the cost and benefit data gleaned from these country case studies. 
Given the constrained nature of the collected cost and benefit data, the efficiency analysis 
has been compelled to lean heavily on assumptions, rather than the preferred reliance on 
empirical evidence. 

The table below shows the status of the case study interviews across the seven case study 
Member States.  

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Table 30.  Status of interview programme for case studies  

Membe
r State 

N.  of  stakeholders 
contacted 

of 

N. 
scheduled 

interviews 

of 

N. 
carried out 

interviews 

NAs 

Indus
try 

NGOs  NAs 

Indus
try 

NGOs  NAs 

Indus
try 

NGOs 

Belgiu
m 

12 

Denmar
k 

8 

France 

8 

German
y 

Malta 

Romani
a 

9 

9 

9 

4 

3 

4 

11 

5 

12 

Poland 

5 

2 

0 

1 

6 

9 

1 

4 

0 

1 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

1 

0 

0 

0 

0 

0 

0 

0 

0 

0 

1 

1 

0 

0 

2 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

The  case  studies  for  the  seven  Member  States  selected  are  provided  in  Annex  5.  When 
relevant, examples and information from the case studies are also included in the main 
body of the report, as part of the findings about the evaluation questions.  

A1.7. A1.8 Summary of robustness of data collection and limitations 

The data collection process encompassed desk research, a comprehensive mapping of the 
legal obligations pertaining to the Governance Regulation, and consultations through a call 
for  evidence,  targeted  surveys,  interviews,  and  a  stakeholder  event,  alongside  in-depth 
research spanning seven case study countries.  

While relevant literature and data were primarily sourced in English, targeted searches in 
other  EU  languages  were  conducted  to  address  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 enhance participation by reaching out to stakeholders directly via email and 
occasionally via telephone and LinkedIn, and reminder emails were also sent. The timeline 
for the consultation was also extended to the maximum extent within the study constraints. 
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.  

Finally,  some  parts  of  the  evaluation  have  had  to  rely  on  very  limited  information  and, 
although  attempts  have  been  made  to  verify  and  triangulate  information  to  the  extent 
possible  (e.g.,  comparing  stakeholder  feedback  across  stakeholder  groups,  and  with 
information  from  secondary  sources),  this  has  not  been  possible  in  all  cases.  Where 
conclusions have been drawn from limited information, this has been explained in the main 
body of the report.  

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The  assumptions  used  in  the  efficiency  analysis  and  the  limitations  of  this  analysis  are 
described in Annex 3. 

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ANNEX 2. SHORT  SUMMARY  ON  THE  FEEDBACK  TO  THE  CALL  FOR 
EVIDENCE  

This  annex  summarises  stakeholders'  responses  to  the  call  for  evidence  on  the 
effectiveness  efficiency,  coherence,  EU  added  value  and  relevance  of  the  Governance 
Regulation. 

A2.1. A2.1 Effectiveness 

Six respondents 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  (in  particular  through  the  introduction  of 
NECPs).613 

However,  several  stakeholders  indicated  that  the  Governance  Regulation  is  not  fully 
achieving  its  objectives.  This  is  related  to  a  number  of  factors,  particularly  linked  to 
National  Energy  and  Climate  Plans  (NECPs)  and  National  Long-Term  Strategies 
(LTSs), which are summarised below.  

  In some cases, the compiling of NECPs is seen as a bureaucratic tool/check-boxing 
exercise rather than a political priority.614 One stakeholder added that NECPs is often 
"a  compilation  of  existing  plans",  rather  than  a  standalone  plan  with  new 
information. This is because several Member States already have national climate 
and/or energy plans in place. Additionally, this has consequences on the obligation 
related to public participation (Article 10): when the NECP is based on existing plans, 
"there is no new content to consult the public on".615 

  The  current  design  of  NECPs  is  not  effective  nor  sufficient  to  address  the  gap 
between measures and objectives.616 Specifically, according to eight respondents, 
the  NECP  template  provided  in  Annex  I  of  the  Governance  Regulation  no  longer 
reflects  the  latest  scientific  progress  or  developments  in  EU  climate  and  energy 
policies.617  

  Given that there is no obligation to ensure coherence between the NECPs and 
LTS, stakeholders raised concerns about whether the NECPs put the Member States 
(and the EU) on the pathway to decarbonisation, in line with the countries’ LTSs and 
the EU’s climate neutrality goal.618 

  According to eight respondents, LTSs are not given enough importance (neither 
in the Governance Regulation nor by EU Member States), with some Member States 
viewing  the  development  of  LTSs  as  a  formality  that  can  be  postponed 
indefinitely.619 The absence of a binding template for LTSs was also mentioned as a 
factor  contributing  to  this  issue.  One  stakeholder  mentioned  that  the  five-year 
timeframe might not be sufficient to include updated information.620 

  As  regards  enforcement,  stakeholders  highlighted  that  Articles  29  to  34  of  the 
Governance  Regulation  have  proven  to  be  ineffective  to  ensure  a  strong 
enforcement framework for climate and energy targets.621 They highlighted that the 

613 NGOs (2); Business Associations (2); Academic (1); Other (1);  
614 NGOs (1); Environmental organisation (1); Academic (1) 
615 Public authority (1) 
616 NGOs (1); Business associations (1); Environmental organisations (2) 
617 NGOs (3); Business associations (4); Environmental organisation (1) 
618 NGOs (4); Environmental organisations (2); Academic (1)  
619 NGOs (6); Environmental organisations (1); Academic (1) 
620 Public authority (1) 
621 NGOs (10); Business associations (1); Environmental organisations (3); Academic (2) 

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current  rules  are  not  sufficient  to  create  a  real  deterrent  effect  and  ensure  that 
Member States stick to their targets. This was also reflected by the late submission 
by several Member States of their draft updated NECPs in June 2023, and their LTSs 
in  2020.  Specifically,  the  stakeholders  highlighted  that  the  current  delivery  gap 
mechanism  (Article  32)  is  not  functioning  effectively,  necessitating  quicker 
intervention  and  greater  transparency  in  discussions  between  the  European 
Commission and Member States to outline the measures being taken. 

  Stakeholders  highlighted  that  Article  10  of  the  Governance  Regulation  is  not 
effective  in  ensuring  public  consultation  in  the  preparation  of  NECPs.622  They 
indicated that public participation has varied significantly across Member States and 
has  frequently  not  been  fully  meaningful.  They  also  pointed  out  that  the  Aarhus 
Convention  Compliance  Committee  found  the  EU  in  non-compliance  with  the 
Convention  because  the  Governance  Regulation  did  not  create  a  sufficiently  clear 
and precise framework for public participation in the NECPs.  

  Some  respondents  also  mentioned  that  Article  11  of  the  Governance  Regulation 
(on  multilevel  dialogue)  is  not  effective  in  ensuring  that  Member  States 
implement  multi-level  governance  processes  when  designing,  implementing  and 
monitoring  national  energy  and  climate  policy.623  Indeed,  the  establishment  and 
regular meetings of multilevel climate and energy dialogues have not happened in 
a structured and systematic way, and the feedback periods were too short to assess 
proposals and to suggest potential amendments.  

Finally, eight stakeholders commented on the climate neutrality target, enshrined in the 
European Climate Law.624 The EU has  an overall  climate neutrality target, which applies 
collectively to the Union, but does not apply to each Member State individually. In other 
words,  the  current  EU  legislative  framework  does  not  envisage  national  climate 
neutrality  targets  nor  a  framework  to  set  binding  national  reduction  targets  for  after 
2030. While some Member States are increasingly recognising the need for economy-wide 
national  climate  neutrality  targets,  significant  inconsistencies  still  exist  across 
Member  States  in  terms  of  standards  of  national  climate  ambition  and  governance 
enabling conditions.  

A2.2. A2.2 Efficiency  

Fewer views were provided on the efficiency of the Governance Regulation. The following 
points were, however, mentioned: 

  The lack of consistency between the different planning instruments set out in the 
Governance  Regulation  hinders  both  the  effectiveness  and  the  efficiency  of  the 
Regulation.625 

  Stakeholders noted the administrative burden associated to the Governance 
Regulation, with multiple planning and reporting processes and requirements. 626 
One stakeholder added that the Governance Regulation has not replaced reporting 
obligations in other areas, but instead added a new layer of reporting, which has 
increased the administrative burden.627 

  As  regards  the  reporting  platforms,  two  public  authorities  indicated  that  the 
reporting platforms used for Member States’ submissions are not efficient.628 One 

622 NGOs (8); Business associations (1); Environmental organisations (3); Academic (1)  
623 NGOs (6); Business associations (1), Environmental Organisation (1). 
624 NGOs (3); Business associations (1); Environmental organisations (3); Company/business (1). 
625 NGOs (1); Other (1) 
626 NGOs (1); Public authority (2) 
627 Public authority (1) 
628 Public authority (2) 

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stakeholder  explained  that  two  different  platforms  are  currently  being  used 
(ReportNET3  and  ReportENER),  which  is  suboptimal  and  hinders  the  efficient 
transfer  of  the  necessary  information.  Another  stakeholder  indicated  that  EU  and 
international  reporting  tools  should  be  interoperable  in  order  to  support  Member 
States to reduce reporting burden.  

A2.3. A2.3 Coherence 

Eight  respondents  indicated  that  there  is  a  lack  of  consistency  between  the  different 
planning  instruments  set  out  in  the  Governance  Regulation.629  This  is  related  to  several 
factors, which are summarised below (internal coherence).  

  EU  Member  States  are  entering  into  a  planning  process  with  the  NECPs, 
REPowerEU chapters, and the Social Climate Plans. However, the timelines of 
these different planning processes are not aligned.630  

  The  sequencing  and  timing  of  the  main  governance  processes  under  the 
Governance  Regulation  and  the  EU  Climate  Law  is  not  coherent. 631  These  are 
currently  partially  out  of  sync  in  a  way  that  means  that  information  (e.g.,  from 
assessments under Articles 6 and 7 of the EU Climate Law) is not available in time 
to inform planning processes under the Governance Regulation – and vice versa. 
  As mentioned above, there is also no obligation to ensure coherence between 
the  NECPs  and  LTS.632  There  is  also  no  mandatory  revision  of  LTS  in  the 
Governance  Regulation:  this  results  in  a  situation  in  which,  although  manifestly 
outdated, the LTS are not in the process of being reviewed (while updated NECPs 
are  going  to  be  submitted  by  the  first  half  of  2024),  entailing  that  the  long-term 
direction remains unclear and misaligned with the short-term action.633  

  The sequencing of NECPs and LTSs is also not coherent, with the first LTS being 

submitted after NECPs, while the former should inform the latter. 634  

Additionally, as mentioned in Annex A2.5 (Relevance), stakeholders highlighted that the 
legislative changes introduced after 2018 have significantly impacted the relevance of 
the Governance Regulation.635 This also affects the external coherence of the Regulation. 
Specifically, stakeholders raised the following issues: 

  The Energy Efficiency Directive (EED) recast includes many new elements for a 
stronger  governance  that  are  not  currently  incorporated  nor  streamlined  into  the 
Governance  Regulation,  including  an  EU  binding  target  of  11.7%  for  final  energy 
consumption.636  There  is  also  little  guidance  on  how  to  calculate  a  fair  national 
energy  efficiency  contribution  (in  contrast  to  national  renewable  energy 
contributions). 637 

  The  same  applies  for  the  Renewable  Energy  Directive  (RED)  revision,  which 
introduced new elements  which are not reflected in the Governance Regulation.638 
  The  NECPs  (due  end  2019)  were  out  of  sync  with  the  Energy  Performance  of 
Buildings  Directive’s  (EPBD)  Long-term  renovation  strategies  (due  in  March 

629 NGOs (5); Environmental organisations (2); Academic (1). 
630 NGOs (1). 
631 Academic (1). 
632 NGOs (4); Environmental organisations (2); Academic (1).  
633 NGOs (1). 
634 NGOs (1); Academic (1) 
635  NGOs  (8);  Business  associations  (2);  Environmental  organisations  (3);  EU  citizen  (1);  Public  authority  (1) 
Other (1); Academic (1) 
636 NGOs (2); Business associations (2); Public authority (1); Company/Business (1); Other (1) 
637 Academic (1) 
638 NGOs (1); Environmental organisations (1); Business association (1) 

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2020),  which  limited  the  positive  synergies  for  national  planning  of  building 
renovations.639  The  recast  EPBD  foresees  that  the  next  Long  Term  Renovation 
Strategies evolving into Building Renovation Plans (BRPs) shall be submitted as part 
of the NECPs. Considering the urgency to scale up renovation based on solid national 
plans, the date for the submission of the first national building renovation plan has 
been set as early as possible. The recast EPBD foresees that the following BRPs will 
be fully synchronised with the NECP cycle. 

  According to one public authority, there are challenges as regards the coordination 
of  timelines  for  the  preparation  of  the  National  Energy  and  Climate  Plan  and  the 
National Air Pollution Control Programme under the National Emissions reduction 
Commitments  Directive  (2016/2284/EU).640  Given  that  the  NECPs  set  out  the 
national energy and climate policy framework, the submission deadline for the final 
NECPs  should  ensure  that  they  are  available  well  in  advance  of  other  plans  and 
programmes to be developed in coherence with that framework. 

  Three  respondents  also  indicated  that,  despite  recent  improvements,  coherence 
between the  climate and energy governance and the EU  economic governance 
need to be strengthened,641 so that the coordination of economic policies at EU level 
becomes an enabler for the achievement of ambitious EU climate and energy goals.  

As  regards  coherence  with  international  processes,  six  stakeholders  indicated  that  the 
alignment between EU climate policy cycles and UNFCCC 5 years common time 
frames  should  be  strengthened,  as  foreseen  by  Article  4(7)  of  the  European  Climate 
Law.642  

A2.4. A2.4 EU added value 

Little  feedback  was  provided  in  the  call  for  evidence  on  the  EU  added  value  of  the 
Governance Regulation. 

According to one stakeholder, through the provisions on NECPs, the Governance Regulation 
appears to positively influence the actions of EU Member States in the field of energy and 
climate.643  As  mentioned  under  effectiveness,  six  respondents  also  mentioned  that  the 
Governance  Regulation  has  streamlined  the  different  climate  and  energy  planning  and 
reporting requirements, in particular through the introduction of NECPs. 644 

A2.5. A2.5 Relevance 

Overall, stakeholders highlighted that the legislative changes introduced after 2018 
have significantly impacted the relevance of the Governance Regulation.645 These 
changes  encompass  the  adoption  of  the  European  Green  Deal,  the  Fit  for  55  package, 
REPowerEU,  the  European  Climate  Law,  and  the  collective  commitment  to  a  long-term 
climate  neutrality  objective.  For  instance,  seven  stakeholders  highlighted  that  elements 
introduced by the new Renewable Energy Directive and the Energy Efficiency Directive are 
not reflected in the Governance Regulation, thus hindering its relevance.646  

Similarly,  stakeholders  underlined  that  recent  geopolitical  event,  including  the 
consequences of the COVID-19 pandemic and Russia's war of aggression against Ukraine, 

639 NGOs (1); Other (1) 
640 Public authority (1) 
641 NGOs (2); Environmental organisations (1) 
642 NGOs (3); Environnemental organisations (2); Public authority (1)  
643 Company/Business (1) 
644 NGOs (2); Business Associations (2); Academic (1); Other (1);  
645  NGOs  (8);  Business  associations  (2);  Environmental  organisations  (3);  EU  citizen  (1);  Public  authority  (2) 
Other (1); Academic (1) 
646 NGOs (2); Business associations (2); Public authorities (2); Other (1) 

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make an update of the Governance Regulation imperative, to ensure it remains relevant 
and fit for purpose.647  

Three stakeholders also pointed out that the EU has not updated its 2018 Long-Term 
Strategy (‘Clean Planet for all Europeans’), which is now outdated and not in line with 
the new EU legislative and policy landscape on energy and climate.648 

In terms of gaps, although NECPs and LTS’s are subject to the access to information and 
access to justice obligations of the Aarhus Convention, six stakeholders underlined that the 
Governance Regulation has no reference nor specific provisions on access to justice.649 

Finally, four respondents underlined that the Governance Regulation does not capture nor 
define the important concept of energy sufficiency. 650  

647 NGOs (4); Business associations (2); Environmental organisations (2); EU citizen (1); Public authority (1) 
648 NGOs (1); Environmental organisations (1); Academic (1) 
649 NGOs (3); Environmental organisations (2); Academic (1);  
650 NGOs (2); Environmental organisations (1); Academic (1) 

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ANNEX 3. DETAILED METHOD ON THE EFFICIENCY ANALYSIS  

This annex sets out the methodology and sources used to analyse the costs and benefits 
of the implementation of the Governance Regulation. Consistently with the content of 
the obligations set by the Governance Regulation, and with the evaluation questions for 
the  efficiency  criterion  defined  by  the  evaluation  framework  (see  section  8.1.2  and 
Annex 4), the focus of the analysis is on the regulatory costs (direct compliance costs) 
and administrative burden (i.e. part of the process and costs of collecting and processing 
information that stems directly from legal obligations and would not exist otherwise651). 
On the other hand, in addition to any streamlining of reporting obligations and resulting 
cost savings, the focus of the analysis is mostly on qualitative benefits.  

A3.1 Sources 

The analysis is carried out using multiple sources and triangulating data where possible. 
The main sources are: 

  Desk research, including analysis of references in Annex 9 ;  
  Call for evidence;  
  Targeted survey;  
  Interviews; and,  
  Case studies.  

In  addition,  the  obligation  mapping  (see  Annex  8)  provided  the  basis  for  the 
identification of the main obligations to be analysed. The  same tool is  used to collect 
data  on  the  costs  and  benefits  of  the  relevant  obligations  for  both  Member  States 
(national  authorities,  but  also  industry  and  NGOs,  when  applicable)  and  for  the 
Commission .  

A3.2 Focus of the analysis 

The analysis focuses on the quantification and monetisation of the key direct cost and 
benefit items for which information was available, which concerned (some of) the direct 
costs  and  benefits  for  the  main  stakeholders.  The  remaining  costs  and  benefits  are 
assessed qualitatively.  

The main stakeholders identified as relevant for the analysis are:  

  Member  States’  authorities  responsible  for  and/or  involved  in  the  reporting 
obligations  set  by  the  Governance  Regulation.  This  category  includes  national 
authorities  (e.g.  ministries  of  environment,  climate  transition,  agencies).  The 
analysis also considers whether regional and/or local authorities are also involved 
in  the  reporting  process  (e.g.  in  Member  States  with  a  federal  institutional 
structure and/or with devolved powers on environmental matters);  

  Industry 

stakeholders,  mainly  business 

organisations 
representing  different  sectors,  including  energy-intensive  sectors.  The  analysis 
considers  whether  and  to  what  extent  these  stakeholders  are  involved  in  the 
reporting process set by the Governance Regulation, and whether they perceive 
any of the expected benefits of the Regulation;  

representative 

  Non-governmental  organisations  active  in  energy,  climate  and  environmental 
matters. The analysis considers whether and to what extent these stakeholders 
are  involved  in  the  reporting  process  set  by  the  Governance  Regulation,  and 
whether they perceive any of the expected benefits of the Regulation.  

651 Better Regulation Toolbox, Tool #56 and Tool #58 

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A3.3 Definition of the baseline for the evaluation 

The  baseline  represents  the  situation  before  the  intervention  started  and  the 
Governance  Regulation  entered  into  force,  and  it  includes  identifying  and  collecting 
information on key indicators, metrics, and relevant data that reflect the situation before 
the start of the initiative (BR Toolbox, Tool #60). The evaluation is then assessing the 
intervention  against  this  baseline,  and  the  key  points  of  comparison  relevant  to  the 
evaluation criteria and questions.  

Considering the nature  and content  of the Governance Regulation, which is meant to 
rationalise  and  streamline  reporting  obligations  of  existing  legislation,  among  other 
objectives,  a  key  step  in  the  definition  of  the  baseline  was  to  identify  the  pieces  of 
legislation within the scope of the Regulation. 

The  consolidated  list  of  the  pieces  of  legislation  within  the  scope  of  the  Regulation  is 
provided  in  Annex  9  and  is  based  on  the  analysis  on  the  energy  and  climate  acquis 
carried  out  when  the  Commission  prepared  its  Governance  Regulation  proposal  and 
reported in a Commission Staff Working Document (SWD) 652. The analysis encompassed 
20 different pieces of legislation for the energy acquis, and one piece of legislation for 
the  climate  acquis  (the  MMR).  With  a  few  exceptions,  all  the  obligations  that  were 
indicated for integration made their  way into the Governance Regulation, while those 
indicated for repeal were repealed from sectorial legislation and removed from the EU 
energy and climate acquis. Finally, obligations recommended to be kept separate were 
maintained as independent obligations, either in general or in sectorial legislation. 

Of  the  76  obligations  identified  as  relevant  for  the  Governance  Regulation  in  the 
Commission’s  SWD,  54  concern  obligations  included  in  energy  legislation  (from  20 
different pieces of legislation) and 22 in climate legislation (all from the MMR).  

Overall, 68 of the 76 obligations are classified as follows:  
  15 are planning obligations (all energy-related); 
  29  are  reporting  obligations  (of  which,  16  are  energy-related  and  13  climate-

related); 

  2 are planning and reporting obligations (one energy- and one climate-related); 

and,  

  22 are monitoring obligations (all in the energy acquis).  

The  remaining  8  obligations  under  the  climate  acquis  cannot  be  assigned  to  either 
planning and/or reporting and/or monitoring types and are classified as ‘others’.653  

Within  the  54  energy-related  obligations,  22  target  the  Commission  and  26  Member 
States.    Four  of  the  remaining  obligations  target  Transmission  Systems  Operators 
(TSOs) in relation to the Electricity Directive, the Gas Directive, the Network Access for 
Cross-Border Electricity Exchanges Regulation and the Network Access for Natural Gas 
Transmission  Regulation.  The  final  two  obligations  target  respectively  the  European 
Network  of Transition  Operators for Energy (ENTSO-E), in relation to  Network Access 
for Cross-Border Electricity Exchanges Regulation and European Network of Transition 
Operators  for  Gas  (ENTSO-G)  in  relation  to  the  Network  Access  for  Natural  Gas 
Transmission  Regulation.  Out  of  the  54  energy-related  obligations  listed  as  relevant 
(and a sub-set of the 76 obligations in scope – see above), 18 were integrated in the 
Governance Regulation, most of them (13) related to energy efficiency, the remaining 

652 SWD(2016) 394 final.  
653  These  eight  ‘other’  obligations  vary  in  nature,  encompassing:  obligations  related  to  the  procedures  for 
completing emission estimates to compile the Union inventory (gap filling); obligations on the review of GHG 
inventories  for  ESD  purposes  and  on  addressing  the  effects  of  recalculations  in  the  ESD;  and  more 
‘organisational’ provisions, about cooperation between Member States and the Union, role of the European 
Environment Agency and Climate Change Committee to assist the Commission.  

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4  related  to  decarbonisation  and  the  internal  energy  market.    The  same  number  of 
obligations  (18)  were  repealed,  most  of  them  relating  to  the  internal  energy  market 
(11)  and  energy  efficiency  (4).  Other  obligations  (11)  were  kept  separate  but  still 
reflected in the Governance Regulation, mostly as part  of the internal energy market 
dimension  (5),  but  also  within  the  energy  security  (3)  and  energy  efficiency  (1) 
dimensions.  

The 22 relevant obligations contained in climate legislation (from the MMR) all fall under 
the decarbonisation dimension, and were all integrated in the Governance Regulation, 
with  the  exception  of  one.  Out  of  the  22  obligations  identified  as  relevant,  8  target 
Member States, 5 the Commission (one of which is the EEA), and 8 both Member States 
and the Commission. The remaining obligation refers to the Climate Change Committee 
to  assist  the  Commission  and  cannot  be  attributed  to  any  of  the  stakeholder  listed 
above.  

However, not all elements of the 76 obligations described above (and in Annex 9) were 
subject of integration and streamlining in the Governance Regulation, which concerned 
elements  relevant  for  national  competent  authorities  on  Member  States  and  EU 
Institutions (mostly the European Commission). As  such, the analysis  focused  on the 
effort  and  costs  to  comply  with  the  Governance  Regulation  obligations  for  Member 
States and EU institutions,  

The comparison between the baseline for the evaluation and the implementation period 
was carried out for the main obligations included in the analysis. However, the results 
need to be taken very cautiously, due to the limited comparability of the figures (as also 
described in the main body of the report).  

A3.4 Main costs and benefits identified  

As part of the refinement of the methodology, the main categories of costs and benefits 
for  each  of  the  stakeholders  impacted  have  been  identified,  and  data  collection  tools 
and  protocols  developed  to  identify  the  most  relevant  ones,  collect  quantitative  and 
(when available) qualitative data for the analysis.  

The table below provides an overview of the categories of costs and benefits identified 
and  included  in  the  data  collection  and  analysis.  Those  marked  with  an  (*)  are 
quantified, while the others are assessed in a qualitative way.  

Table 31.  Categories of costs and benefits identified 

Stakehold
er group 

Direct costs identified 

Direct benefits identified  

Member 
States  

Direct compliance costs for planning 
and reporting obligations, including: 

IT 

infrastructure, 

  Adjustment costs (one-off costs) 
for adapting national planning and 
reporting systems and processes to 
Governance  Regulation,  including 
those  for  developing  or  adapting 
e.g. 
the 
transposition  and  implementation 
of  legislation  and  the  adoption  of 
plans  and  reports,  introduction  of 
/ 
organisational 
establishment  of  processes,  cost 
for  organising  the  consultation  on 
draft NECP, possible external costs 
such  as  external  consultancy  and 
support)  (*) 

changes 

Adjustment  costs  (annual  basis, 
recurrent  costs)  for  complying  with 

  Savings in time and/or resources for 
planning  and  reporting  thanks  to 
rationalisation, use of templates and 
IT tools, among others (*)  

 

Improved  quality  and  timeliness  of 
information produced  

  Higher  visibility  of  different  but 

interconnected policy domains  

  Direct  export  of 

information 

in  easily 
readable and editable formats for reuse in 
international  reporting  obligations  (e.g. 
GST, AC) 

  Higher  coherence  of  planning  and 
reporting timelines and procedures 

  Higher  coordination  of  different 
competent authorities/Ministries  

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Stakehold
er group 

Direct costs identified 

Direct benefits identified  

  Better established processes, policies 

and procedures  

planning  and  reporting  obligations, 
e.g.:  

  Administrative costs to comply with 
planning and reporting obligations, 
e.g.  cost  of  ongoing  coordination 
between 
entities 
different 
compiling or providing data, cost of 
preparing/  submitting  reports,  IT 
maintenance 
possible 
external  costs  such  as  external 
consultancy and support) (*)  

costs, 

  Administrative  burden  related  to 
planning and reporting obligations, 
in  addition  to  the  ‘business  as 
usual’ scenario (*)  

  Adjustment 
related 
to 
costs 
consultation 
coordination 
and 
mechanisms  in  place,  such  as 
participating in physical and online 
meetings,  preparing  meetings  etc. 
(*)  

European 
Institutions 
(European 
Commissio
n 
European 
Environmen
tal Agency) 

and 

Direct 
compliance 
monitoring obligations, including:  

costs 

for 

 

Improved planning of policies 

  Better investor certainty 

  Adjustment costs (one-off costs) 
: e.g. legislative changes (revision 
or renewal of legislation, provision 
of templates, introduction of a new 
legislative  act),  preparation  of 
guidance  documents  for  Member 
States, 
ICT/  equipment  costs, 
outsourcing  costs  (consultancy, 
support, if any)  (*) 

Adjustment  costs  (annual  basis, 
recurrent 
for  monitoring 
obligations, including:  

costs) 

  Assessing  progress  of 

reporting 

entities 

  Checking  compliance  of  reporting 

entities 

  Awarding derogations/exemptions to 

reporting entities 

 

Improved  quality  and  timeliness  of 
information 

  Higher  coherence  of 

information 

available for policy-making 

  Administrative 

costs: 

e.g. 
information  and  monitoring  costs 
to  comply  with  monitoring  costs; 
IT/equipment  maintenance  costs, 
outsourcing  costs  (consultancy, 
support, if any) (*)  

coordination 

Increased 
different 
authorities/Ministries 

between  
competent 

 

 

  Administrative  burden  related  to 
monitoring  obligations,  in  addition 
to the ‘business as usual’ scenario/ 
(*)  

  Adjustment 
related 
to 
costs 
consultation 
coordination 
and 
mechanisms  in  place,  such  as 
participating in physical and online 
meetings,  preparing  meetings, 
secretariat etc (*) 

Industry 

No major costs identified  

  Better  information  about  the  Energy 

Union implementation 

  Better investor certainty 

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Stakehold
er group 

Direct costs identified 

Direct benefits identified  

Citizens 

No major costs identified  

  Better  information  about  the  Energy 

Union implementation 

A3.5 Quantifications of costs and benefits 

As per the ToR requests and per the BRGs, the analysis is based on the Tools #56 to 
#58,  and  used  to  the  extent  possible  the  categorisation  and  quantification  of  costs 
related  to  the  planning,  reporting  and  monitoring  obligations  set  by  the  Governance 
Regulation and the procedures and tools created for its implementation. The costs and 
benefits quantified and monetised for the different categories of stakeholders (Member 
States,  the  Commission  and  the  European  Environmental  Agency  especially)  can  be 
compared to those quantified in the baseline, with some caution.   

The costs and (to the extent possible) the administrative and financial benefits for the 
key  stakeholders  (Member  States,  the  Commission  and  the  European  Environmental 
Agency)  are  estimated  in  euro  values  and  in  current  prices  (2023  prices).  The 
quantification  of  costs  followed  to  the  extent  possible    the  general  approach  to  SMC 
analysis detailed in the BR Toolbox (Tool #58). This section details the approach adopted 
for the quantification  of costs for both Member States and the European Commission 
(and Agencies, EEA especially).  

The  analysis  was  based  on  data  and  information  collected  throughout  the  study,  via 
desk  research,  targeted  interviews  and  case  studies  in  selected  Member  Staes. 
However, evidence collected provided limited and fragmented information on the current 
costs of implementing the Governance Regulation for Member States and the European 
Commission due to several reasons:  

  Difficulties in mobilising stakeholders in the relevant national administrations in 
Member  States  selected  for  the  case  studies,  despite  many  efforts  and  many 
different channels used; 

  Partial knowledge among the stakeholders reached by the consultation activities 
of the interactions among different administrations, and fragmentation of some 
of the procedures in place to comply with the Governance Regulation obligations;  
  Limited knowledge among many of the stakeholders reached of the situation in 
place  before  the  Governance  Regulation  entered  into  force,  so  that  they  could 
not make an informed evaluation (even in qualitative terms) of the evolution of 
activities and costs compared to the baseline;  

  Related to the previous point, lack of information on one-off implementation costs 

related to the Governance Regulation.  

The analysis therefore is based on a set of assumptions and simplifications and needs 
to be taken with some caution.  

In  consideration  of  the  limited  evidence  available,  the  analysis  focuses  on  the  direct 
compliance  costs  for  both  national  authorities  in  Member  States  and  the  European 
Commission,  and  considers  both  the  direct  staff  costs,  and  the  external  costs  (e.g. 
consultancies  and  research  institutes  contracted  by  national  authorities  and/or  the 
European  Commission  to  support  them  in  complying  with  the  different  reporting 
obligations imposed by the Governance Regulation).  

Very  limited  data  was  collected  on  IT  costs.  Concerning  Member  States,  none  of  the 
national  competent  authorities  consulted  (via  survey,  targeted  interviews  and  case 
studies)  reported  IT  costs  related  to  the  Governance  Regulation,  either  directly  (to 
provide  the  information  requested)  nor  indirectly  (to  adapt  national  systems  to  the 
information needs of the Governance Regulation). Data collected on IT costs for the EU 

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institutions concerned the costs for the design, implementation and maintenance of the 
e-platform.  

Very limited evidence was also collected on external (e.g. outsourcing costs) related to 
the Governance Regulation, especially concerning national competent authorities. While 
in  the  case  studies  several  of  them  confirmed  that  they  are  supported  by  external 
consultants for different elements of the Governance Regulation obligations (from GHG 
projections to public consultations to compiling of data and drafting of reports), they did 
not divulge information on the amounts of such contracts654 Indicators and proxies had 
to be used, to provide possible indications of outsourcing costs.  

No  evidence  was  collected  on  the  adjustment  costs  encountered  to  comply  with  the 
Governance Regulation, either for Member States or for the EU institutions. Qualitative 
information collected from Member States highlighted how the Governance Regulation 
required a much stronger cooperation among different national competent authorities 
and their different departments, which in some cases led to a broad process of design 
or re-design of processes and (in some instances still ongoing). Unfortunately, none of 
the primary sources of information (surveys, targeted interviews, case studies) provided 
quantitative  indications  of  the  efforts  (and  costs)  of  this  redesign  processes. 
Assumptions had to be made, based on available literature (see details in the following 
sub-sections).  

A3.5.1 Costs for Member States  

As far as compliance costs for Member States are concerned, data collected included all 
the main planning and reporting obligations of the Governance Regulation, namely:  

  NECP (Article 3, Article 4, Annex I) 
  NECPR (Article 17) 
  Long-term strategies (Article 15) 
  Integrated reporting on greenhouse gas policies and measures and on projections 

(Article 18, , Annex I) 

  National Climate Change Adaptation Planning and Strategies (NAP/NAS) (Article 

19(1))  

  Annual  reporting,  including  oil  stocks,  offshore  safety  and  greenhouse  gas 

inventory data (Article 26) 

  Reporting on 2020 targets (Article 27, one-off obligation). 

To compensate at least partially for the limited availability of data, was decided to group 
the Member States in clusters, and to use the data available to provide a more accurate 
estimation of costs for Member States within more homogeneous groups.  

Taking into account some of the criteria used to identify the Member States for the case 
studies, three criteria were used to group Member States:  

  Size, based on the population – Member States with a population below 10 million 
inhabitants were classified as ‘small countries’, those with a population between 
10 and 60 million inhabitants were classified as ‘medium-sized countries’, while 
those  with  a  population  of  60  million  inhabitants  and  above  were  classified  as 

654 The study team made it clear to the interviewee that no specific details were needed, and that simply the 
indication of the order of magnitude of such contracts would have been sufficient to provide indications useful 
to the analysis.  

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‘large  countries.  Data  on  population  was  e  taken  from  Eurostat  statistics  on 
population for 2022 (last year available).655  

  Institutional  organisation  (i.e.  centralised,  devolved  or  federal  administration), 
since  it  is  considered  that  a  devolved/federal  institutional  set-up  may  require 
additional  coordination  among  the  competent  central  and  regional/local 
administrations (and thus possibly higher costs).  

  Member  States’  capacity  comply  with  the  planning,  reporting  and  monitoring 
obligations  existing even before the  Governance Regulation  entered into force. 
This was measures by looking at the submission date of GHG inventory data for 
both 2018 and 2019 as reported in the Annual European Union greenhouse gas 
inventory and inventory reports for 2018 and 2019.656 The use of GHG inventory 
data was considered the most suitable proxy for this parameter, since the same 
obligation was in force before the Governance Regulation entered into force (as 
part  of  the  MMR),  and  then  was  included  in  the  Governance  Regulation,  thus 
presented  the  least  disruption  in  the  change  of  legislative  framework.  Member 
States were divided in two groups, one including those countries that somewhat 
improved their compliance between 2018 and 2019 (measures by a reduction in 
the  delay  of  submission  of  GHG  inventory  data)  and  another  including  those 
whose  compliance  slightly  worsened  from  2018  to  2019  (measured  by  an 
increase in the delay of submission of GHG inventory data.  

Three  clusters  resulted  from  this  exercise,  as  presented  in  the  table  below,  together 
with the main assumptions of FTEs used for estimating the staff costs to comply with 
the  main  obligations  of  the  Governance  Regulation.  The  effort  estimations  were 
calculated using data from the case studies.  

Table 32.  Overview of Member States’ clusters 

Group 

Group A 

Group B 

Group C 

Description 

Composition 

and 
a 

Small 
countries, 
with  a  centralised 
institutional 
organisation 
showing 
somewhat 
improving  capacity 
comply  with 
to 
planning, reporting 
monitoring 
and 
obligations 
over 
time 

Bulgaria,  Croatia, 
Cyprus,  Denmark, 
Finland, 
Estonia, 
Hungary,  Ireland, 
Latvia,  Lithuania, 
Luxembourg, 
Malta, 
Netherlands, 

the 

with 

Medium-sized 
countries, 
different 
institutional 
organisations, 
showing  a  limited 
capacity  to  comply 
planning, 
with 
reporting 
and 
monitoring 
obligations 
time 

over 

a 

countries, 
different 

Large 
with 
institutional 
organisations, 
showing 
somewhat 
improving  capacity 
comply  with 
to 
planning,  reporting 
monitoring 
and 
obligations 
over 
time 

Austria,  Belgium, 
Republic, 
Czech 
Poland, 
Greece, 
Portugal,  Romania, 
Spain, and Sweden.  

France,  Germany 
and Italy.  

data 

Eurostat 

655 
https://ec.europa.eu/eurostat/databrowser/view/DEMO_GIND/default/table?lang=en  
656  See  https://www.eea.europa.eu/publications/european-union-greenhouse-gas-inventory-2018  and 
https://www.eea.europa.eu/publications/european-union-greenhouse-gas-inventory-2019 

[demo_gind], 

population 

available 

January 

at: 

on 

on 

1 

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Group 

Group A 

Slovakia, 
Slovenia 

and 

Group B 

Group C 

Effort  for  NECP 
(frequency:  every 
five years)657 

12-15 FTEs 

15-20 FTEs 

20-25 FTEs 

Effort for NECPR 

6-8 FTEs 

8-10 FTEs 

10-12 FTEs 

(frequency:  every 
two years) 

Effort for LTSs 

8-12 FTEs 

12-15 FTEs 

15-20 FTEs 

(frequency:  every 
10 years) 

for  GHG 
and 

Effort 
reporting 
projections 
(frequency:  every 
two years) ) 

2-3 FTEs 

3-4 FTEs 

5-6 FTEs 

Effort 
NAP/NAS 

for 

2-5 FTEs 

5-7 FTEs 

8-10 FTEs 

(frequency:  every 
two years) 

Effort  for  Annual 
reporting  

(frequency:  every 
year) 

2-3.5 FTEs 

3.5-5- FTEs 

5-6.5 FTEs 

Effort 
stocks 

for 

oil 

0.25-0.5 FTEs 

0.5-0.75 FTEs 

0.75-1 FTEs 

(frequency:  every 
year) 

Effort for offshore 
safety 

(frequency:  every 
year) 

Effort 
inventory data 

for  GHG 

(frequency: annual) 

Effort 
for 
reporting on 2020 
targets 

0.25-0.5 FTEs 

0.5-0.75 FTEs 

0.75-1 FTEs 

1.5-2.5 FTEs 

2.5-3.5- FTEs 

3.5-4.5 FTEs 

2-5 FTEs 

5-7- FTEs 

8-10 FTEs 

657 The analysis includes the full process, encompassing the draft and the final report 

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Group 

Group A 

Group B 

Group C 

(frequency: 
off) 

one-

Data on staff costs were taken from Eurostat statistics on salary data for staff employed 
in public administration in the EU for 2023. 658  

The data on FTEs necessary to comply with the different obligations were multiplied by 
a coefficient reflecting their frequency over the years covered by this evaluation (e.g. 
coefficient of 1 in case of annual obligations, coefficient of 0.5 for obligations due every 
two years). This was done to allow for calculating the annual costs of complying with 
the  Governance  Regulation  for  Member  States,  and  for  an  easier  comparison  of  the 
effort and cost of each obligation.  

Table 33.  As mentioned above, little to no evidence was collected on adjustment costs 
for  staff,  beside  general  considerations  on  the  much  stricter  cooperation 
among  national  authorities  needed  to  comply  with  the  Governance 
Regulation,  and  the  (sometimes  still  ongoing)  redesign  of  processes  and 
procedures. To provide  some indication  on the  extent  of adjustment costs, 
the  study  considered  the  estimates  for  such  costs  included  in  the  Fitness 
Check659  and  in  the  SWD  supporting  the  introduction  of  the  Governance 
Regulation660, both for the energy and the climate components. Both studies 
provided estimates of one-off and running costs related to the Governance 
Regulation. To make the exercise more meaningful, the study only took into 
account the cost items that were relevant to both the supporting studies for 
the Governance Regulation and the current evaluation. Details are provided 
in the table below. The analysis calculated the share of one-off costs over the 
running costs for staff as estimated by these two documents – which were 
widely  diverging  –  and  used  an  average  value  (20%).  Details  of  one-off 
adjustment costs for staff from available documents  

From  Fitness  Check  IA  estimations  (ENER  component)  (Policy  Option 
3b, p 163) 

Implementation of single act via ministerial order 

•  Development  of  the  ministerial  order  (3-5 
person months):  

EUR  

308,000 

• Discussion in a working group 

EUR  

756,000 

TOTAL 

TOT running costs 

 EUR 

1,064,000 

658  Eurostat  data  on  Average  remuneration  of  national  civil  servants  in  central  public  administration 
[prc_rem_avg__custom_10621770],  nominal 
at: 
https://ec.europa.eu/eurostat/databrowser/view/prc_rem_avg/default/table?lang=en&category=prc.prc_re
m  
659  Trinomics  (2016)  Preparatory  study  for  the  Commission’s  Fitness  Check  Evaluation  of  Planning  and 
Reporting Obligations in the EU Energy acquis 
660 SWD(2016) 394 final 

terms,  2023 

semester), 

available 

(second 

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Final Evaluation Report 

Implementation 

 EUR 

8,200,000 

Administrative and reporting costs 

 EUR 

6,700,000 

Outsourcing 

TOTAL 

 EUR 

5,300,000 

 EUR 

20,200,000 

% one-off vs recurring 

5% 

From IA Proposal for a Regulation of the European Parliament and the 
Council on the Governance of the Energy Union (p. 103, Table 15) 

Option  S4  (single  act  replacing  relevant  parts  of  energy  acquis  and 
MMR)  and  Option  S5  (single  act  replacing  relevant  parts  of  energy 
acquis and fully replacing MMR) 

Implementation costs for Member States 

One-off costs 

Annual costs 

EUR 

7,600,000 

EUR  

20,100,000 

% one-off vs recurring 

38% 

The lack of evidence regarding external costs, particularly regarding the extent to which 
Member  States  rely  on  consultancies  or  other  external  parties  to  comply  with  the 
obligations of the Governance Regulation, did not allow for an estimation based on data 
collected from case studies. Notably, case studies reveal that some Member States, such 
as Poland, Germany, and Romania, have received some support, including contractual 
agreements with external entities. However, the specifics on the amounts or durations 
of these contracts have not been disclosed.  

To supplement this information gap, it was decided to use data on projects implemented 
by the European Commission’s DG REFORM through procurement since July 2019. These 
projects  fall  under  two  EU  programmes:  the  Technical  Support  Instrument  (TSI), 
providing tailor-made technical expertise to EU Member States to design and implement 
reforms  since  2021,  and  its  predecessor,  the  Structural  Reform  Support  Programme 
(SRSP) for 2017-2020. The TSI assistance covers various policy areas, with the analysis 
focusing on projects related to Energy Union, energy and climate policies, given their 
relevance  to  the  Governance  Regulation.  This  source  is  used  as  a  proxy  for  gaining 
insights on the extent of overall external costs This approach has limitations, such as 
excluding  any  external  cost  linked  to  national  procurement  processes  and  attributing 
the full cost to the compliance with the Governance Regulation, while it may be only a 
component  of  the  overall  project.  Furthermore,  the  values  available  from  the  tracker 
represent  the  maximum  value  of  the  contracts,  not  considering  possible  discount 
provided by the contractors as part of the procurement process. Nevertheless, this proxy 
can  provide  an  indication  of  the  number  of  Member  States  requesting  some  form  of 
external support, and of the costs linked to it.   

A3.5.2 Costs for the European Commission and Agencies  

European Institutions have  also borne costs related to the obligations of the Governance 
Regulation.  The  below  table  provides  an  estimate  of  the  total  number  of  European 
Commission  staff  (FTE)  working  on  the  Governance  Regulation.  The  figure  is  an 

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estimation,  based  on  previous  studies  and  on  expert  assessment  by  the  EU 
Commission’s  Directorate-Generals  most  involved  in  the  implementation  of  the 
Governance  Regulation  (DG  ENER  and  DG  CLIMA).  Those  estimations  are  to  be 
considered inclusive of costs (staff and outsourcing) of all EU institutions involved in the 
implementation of the Governance Regulation, including support by Agencies. The scope 
of  the  evaluation  included  all  the  obligations  already  analysis  for  Member  States’ 
national competent authorities, as well as of the obligations related to the preparation 
of the State of the Energy Union (Article 35).  

The costs reported also include outsourcing costs (when relevant), both among one-off 
and recurring costs.  

Same as for costs for Member States, the costs for the EU institutions are reported on 
an annual basis, for an easier comparison of the effort and cost of each obligation.  

Finally, IT costs were reported for the design, implementation and maintenance of the 
e-platform. Figures were in line with the estimates included already in the SWD.  

Total annual costs for staff time are estimated based on the Administrator (AD7, step 
1)  entry  salary  (EUR  7.050,14  per  month)  as  reported  2023  Annual  update  of  the 
Remuneration and Pensions of the Officials and other servants of the European Union 
and the correction coefficients applied thereto (C/2023/1544).661.  

These costs pertain the different activities carried out by the European Institutions to 
apply the Governance Regulation, which include, among others, revision and comment 
to national reports (e.g. NECPs, NECPRs., GHG repository and inventories), preparation 
of  own  reports  and  documents  (e.g.  State  of  the  Energy  Union,  UN  reporting 
obligations), coordination of tasks among different DGs and Agencies, and support to 
Member States’ national administrations.   

661 As per 2023 Annual update of the Remuneration and Pensions of the Officials and other servants of the 
European Union and the correction coefficients applied thereto (C/2023/1544) for Grade Administrator 7 (step 
1).. See: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ%3AC_202301544  

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Table 34.  Estimation of EU institutions’ costs for implementing the Governance Regulation  

Obligation 

Art. 

Frequency 
obligation 

of 

One-off adjustment costs 

Recurring adjustment costs 

r
e
p
(

s
E
T
F

)
e
s
i
c
r
e
x
e

n
e
m
p
u
q
E

i

,
e
r
a
w

t
f
o
s

)
R
U
E
(

c
t
e

,
t

s
t
s
o
c

g
n

i
c
r
u
o
s
t
u
O

)
R
U
E
(

f
i
(

r
e
h
t
O

s
t
s
o
c

)
R
U
E

y
n
a

r
e
p
(

s
E
T
F

)
e
s
i
c
r
e
x
e

NECP 

MS LTS 

NECPR 

4 

3, 
annex I 

Every  5  years  (covers 
both draft and final) 

15 

17 

Every 10 years 

One-off 

GHG policies and projections  18 

Every 2 years 

NAP/NAS 

Annual reporting  

Oil stocks 

Offshore safety 

 GHG inventory data 

Reporting on 2020 targets 

19 

26 

26 

26 

26 

17 

SOEUR 
reporting) 

(cumulated 

35 

Every 2 years 

Every 2 years 

Every year 

Every year 

Every year 

One-off 

0 

0 

2 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

500,000 

0 

0 

0 

0 

0 

0 

0.5 

0 

100,000 

200,000 

0 

0 

0 

0 

0 

9 

0 

0 

0 

0 

0 

0 

0 

10 

4 

5 

6 

4 

3.7 

0.1 

0.1 

3.5 

0 

3.15 

n
e
m
p
u
q
E

i

,
e
r
a
w

t
f
o
s

,
t

s
t
s
o
c

g
n

i
c
r
u
o
s
t
u
O

)
R
U
E
(

1,100,000 

280,000 

350,000 

0 

0 

0 

0 

0 

0 

0 

600,000 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

f
i
(

r
e
h
t
O

s
t
s
o
c

)
R
U
E

,
y
n
a

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

June, 2024 

217 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

Obligation 

Art. 

Frequency 
obligation 

of 

One-off adjustment costs 

Recurring adjustment costs 

r
e
p
(

s
E
T
F

)
e
s
i
c
r
e
x
e

n
e
m
p
u
q
E

i

,
e
r
a
w

t
f
o
s

)
R
U
E
(

c
t
e

,
t

s
t
s
o
c

g
n

i
c
r
u
o
s
t
u
O

)
R
U
E
(

f
i
(

r
e
h
t
O

s
t
s
o
c

)
R
U
E

y
n
a

r
e
p
(

s
E
T
F

)
e
s
i
c
r
e
x
e

n
e
m
p
u
q
E

i

,
e
r
a
w

t
f
o
s

,
t

s
t
s
o
c

g
n

i
c
r
u
o
s
t
u
O

)
R
U
E
(

f
i
(

r
e
h
t
O

s
t
s
o
c

)
R
U
E

,
y
n
a

SOEUR 

35 

pre-existing,  but  no 
legal base 

NECPR assessment report 

35 

cost  covered  under 
NECPR 

Carbon market report 

35 

Every year 

Bioenergy 
report 

sustainability 

35 

Voluntary schemes report 

Gas internal market report 

35 

35 

Electricity 
report 

internal  market 

35 

EEOS report 

Renovation report 

NZEB report 

Internal market report 

Fuel quality report 

35 

35 

35 

35 

35 

Every 2 years 

Every 2 years 

Every year 

Every year 

Every year 

Every 2 years 

Every 4 years 

Every year 

Every year 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

1 

0 

0.25 

0.1 

0.1 

0.1 

0.1 

0.1 

0.15 

0.1 

0.1 

0.1 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

300,000 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

June, 2024 

218 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

Obligation 

Art. 

Frequency 
obligation 

of 

One-off adjustment costs 

Recurring adjustment costs 

r
e
p
(

s
E
T
F

)
e
s
i
c
r
e
x
e

n
e
m
p
u
q
E

i

,
e
r
a
w

t
f
o
s

)
R
U
E
(

c
t
e

,
t

s
t
s
o
c

g
n

i
c
r
u
o
s
t
u
O

)
R
U
E
(

f
i
(

r
e
h
t
O

s
t
s
o
c

)
R
U
E

y
n
a

r
e
p
(

s
E
T
F

)
e
s
i
c
r
e
x
e

n
e
m
p
u
q
E

i

,
e
r
a
w

t
f
o
s

,
t

s
t
s
o
c

g
n

i
c
r
u
o
s
t
u
O

)
R
U
E
(

f
i
(

r
e
h
t
O

s
t
s
o
c

)
R
U
E

,
y
n
a

competitiveness report 

subsidies report 

CAPR 

CCS report 

TOTAL 

35 

35 

35 

35 

Every year 

Every year 

Every year 

Every year 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

2.5 

100,000 

700,000 

0 

0 

0 

0 

9 

0.25 

0.1 

0.5 

0.1 

43 

0 

0 

0 

0 

0 

0 

300,000 

0 

0 

2,930,000 

0 

0 

0 

0 

0 

June, 2024 

219 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
Final Evaluation Report 

A3.1.1. Main challenges and limitations   

As described above, the challenges of the exercise were represented by the scarcity of the 
data  collected  via  the  different  sources,  and  of  the  partial  knowledge  of  the  full  set  of 
activities and costs related to those by many of the stakeholders reached.  

As a consequence, the analysis had to rely heavily on estimations and assumptions, which 
resulted in several limitations:  

  Absence of data collected on one-off implementation costs. It was not possible to 
collect  any  evidence  from  the  different  primary  sources  scrutinised.  The  analysis 
looked  therefore  to  the  estimations  included  in  the  preparatory  studies  and  SWD 
prepared for the Commission’s impact assessment for the Governance Regulations. 
Since  the  preparatory  studies  were  in  turn  based  on  estimations,  the  figures 
presented by the analysis  suffer from any  over-  or under-estimation in the initial 
exercises. Nevertheless, triangulation between the available sources helped provide 
a somewhat more robust indication. .  

  The  recourse  to  proxy  for  estimating  the  external  costs  for  Member  States.  The 
proxy  used  (the  project  financed  via  the  Technical  Support  Instrument  (TSI)  and 
the Structural Reform Support Programme (SRSP), do not cover any external cost 
linked to national procurement processes. Furthermore, attributing the full costs of 
those  projects  to  the  compliance  with  the  Governance  Regulation  could  lead  to 
overestimations, since only a component of the overall project may be attributable 
to  the  Governance  Regulation.  Finally,  the  values  available  from  the  tracker 
represent  the  maximum  value  of  the  contracts,  not  considering  possible  discount 
provided by the contractors as part of the procurement process.  

  The  continuous  evolution  of  the  policy  and  legislative  framework  relevant  to  the 
planning,  monitoring  and  reporting  obligations  set  in  the  Governance  Regulation 
makes it even more difficult to make comparisons over time. The EU policy evolved 
to  include  several  new  elements  within  the  five  years  covered  by  the  evaluation 
(e.g. European Green Deal, European Climate Law, Fit for 55). Furthermore, every 
time one of the pieces of legislation whose reporting obligations are integrated in 
the Governance Regulation is amended, the Governance Regulation need to align 
the reporting obligations with the new needs. While the changes introduced by Fit 
for 55  are are still to be reflected in future NECPRs, updates to the NECPs to reflect 
the  changing  legislative  landscape  were  managed  via  additional  guidance  and 
support provided to Member States via Working Groups. This implies additional work 
from both the European Commission and  Member States, to identify the changes 
needed, adapt the templates and formats of the reporting, and align the information 
collected  and  elaborated.  The  legislative  procedures  for  revising  the  Energy 
Efficiency Directive (Directive 2010/31/EU) and the Energy Performance of Buildings 
Directive (Directive 2010/31/EU) are recent examples.662  

Overview of benefits and costs 

Consistently with the BR Toolbox (Tool #49)663, the evaluation identified and quantified to 
the extent possible the costs  and benefits  related to the  Governance  Regulation. It also 
tried  to  identify  any  simplification  and  reduction  of  administrative  burden  related  to  the 
Governance Regulation, and any potential for further  simplification.  The results  of these 
analyses are included inTable 35  and Table 36  respectively.  

See: 

662 
https://energy.ec.europa.eu/topics/energy-efficiency/energy-efficiency-targets-directive-and-
rules/energy-efficiency-directive_en  and  https://energy.ec.europa.eu/topics/energy-efficiency/energy-efficient-
buildings/energy-performance-buildings-directive_en respectively 
663  European  Commission 
https://commission.europa.eu/law/law-making-process/planning-and-proposing-law/better-regulation/better-
regulation-guidelines-and-toolbox_en   

July  2023,  available  at: 

(July  2023) 

regulation’ 

toolbox 

‘Better 

June, 2024 

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Table 35.  Overview of benefits and costs  

Overview of costs and benefits identified in the evaluation 

Citizens/Consumers  

Businesses 

Administrations 

European  Commission’s 
services 

Quantitative   Comment 

Quantitative   Comment 

Quantitativ
e 

Comment  

Quantitativ
e 

Comment 

Costs 

Direct compliance costs  

administrative costs 

One-off 
costs 

N/A 

N/A 

Citizens/cons
umers are not 
subject to any 
obligations 
related  to  the 
implementati
on 
of 
Compliance 
Regulation 

the 

Businesses are 
not  subject  to 
any 
obligations 
related  to  the 
implementatio
n 
of 
Compliance 
Regulation 

the 

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

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

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

on 

Figures 
based 
estimates 
derived  from 
previous 
studies 
accompanyi
ng 
Governance 
Regulation 

the 

Reporting  on 
2020  targets 
is  a  one-off 
obligation, 
hence 
reported 
here 

Costs 
largely 
relying  on 
self-
assessment 
from 
EU 
institutions  

costs: 

Outsourcin
g 
EUR 
700,000 
(or  which 
EUR 
500,000 
related  to 
NECP  and 
EUR 
200,000  of 
reporting 
on 
targets) 
(2023 
prices) 

2020 

Staff 
costs:  EUR 
100,000 
related  to 
reporting 

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Overview of costs and benefits identified in the evaluation 

Citizens/Consumers  

Businesses 

Administrations 

European  Commission’s 
services 

Quantitative   Comment 

Quantitative   Comment 

Quantitativ
e 

Comment  

Quantitativ
e 

Comment 

2020 

on 
targets) 
(2023 
prices) 

costs: 
IT 
5 
EUR 
million  for 
design  and 
implement
ation of  e-
platform  

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

2020 

Reporting 
on 
targets: 
EUR 
million 
EUR 
million 
(2023 
prices) 

0.8 
to 
1.3 

Direct compliance costs  

administrative costs 

N/A 

Recurre
nt  costs 
(yearly 
costs) 

N/A 

Citizens/cons
umers are not 
subject to any 
obligations 
related  to  the 

Businesses are 
not  subject  to 
any 
obligations 
related  to  the 

NECP:  EUR 
2.9  million 
to  EUR  3.7  
million 

These 
figures  are 
on 
based 
estimations, 
to 
due 

NECP: EUR 
431,000  
(2023 
prices) 

Costs 
largely 
relying  on 
self-
assessment 

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Overview of costs and benefits identified in the evaluation 

Citizens/Consumers  

Businesses 

Administrations 

European  Commission’s 
services 

Quantitative   Comment 

Quantitative   Comment 

Quantitativ
e 

Comment  

Quantitativ
e 

Comment 

implementati
on 
of 
Compliance 
Regulation 

the 

implementatio
n 
of 
Compliance 
Regulation 

the 

(2023 
prices) 

of 

scarcity 
data 
available. 

years. 

3.7  
to 
4.7  

NECPR: 
EUR 
million 
EUR 
million 
(2023 
prices) 

: 
1.1  
to 
1.4  

National 
LTSs: 
EUR 
million 
EUR 
million 
(2023 
prices) 

GHG 
reporting 

from 
EU 
institutions  

NECPR: 
EUR 
439,375 
(2023 
prices) 

National 
LTSs:  EUR 
70,300 
(2023 
prices) 

GHG 
policies 
and 
projections
: 
EUR 
317,250 
(2023 
prices) 

NAP/NAS: 
EUR 

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Overview of costs and benefits identified in the evaluation 

Citizens/Consumers  

Businesses 

Administrations 

European  Commission’s 
services 

Quantitative   Comment 

Quantitative   Comment 

Quantitativ
e 

Comment  

Quantitativ
e 

Comment 

and 
projections   

1.4  
to 
1.9 

EUR 
million 
EUR 
million 
(2023 
prices) 

NAP/NAS 
1.9 
EUR 
to 
million 
EUR 
3.2 
million  per 
year, 
(2023 
prices) 

Annual 
reporting 
(cumulativ
e): 
EUR 
2.9  million 
to  EUR  4.5 
million 

211,500 
(2023 
prices) 

Annual 
reporting  : 
EUR 
391,275 
(2023 
prices),  of 
which  EUR 
21,150  for 
reporting 
on 
oil 
stocks  and 
offshore 
safety, and 
EUR 
370,125 
for 
reporting 
on 
inventory 
data 

GHG 

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Overview of costs and benefits identified in the evaluation 

Citizens/Consumers  

Businesses 

Administrations 

European  Commission’s 
services 

Quantitative   Comment 

Quantitative   Comment 

Quantitativ
e 

Comment  

Quantitativ
e 

Comment 

(2023 
prices)  of 
which  EUR 
0.8  million 
to  EUR  1.3 
million  for 
reporting 
gas 
on 
stocks  and 
offshore 
safety, and 
1.7 
EUR 
to 
million 
EUR 
2.5 
million  for 
GHG 
Inventory 
data 

State 
of 
the  Energy 
Union 
report 
(SOEUR): 
EUR 
748,744 
(2023 
prices) 

IT costs for 
maintenan
ce  of  e-
platform: 
EUR 
750,000 

Benefits 

Benefits: 

September, 2024 

N/A 

Recurre
nt  

Contribution 
to  creating  a 
stable 
framework  for 

increased 
transparenc N/A 

225 

 
 
 
 
                        
 
 
 
 
 
 
 
 
 
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Overview of costs and benefits identified in the evaluation 

Citizens/Consumers  

Businesses 

Administrations 

European  Commission’s 
services 

Quantitative   Comment 

Quantitative   Comment 

Quantitativ
e 

Comment  

Quantitativ
e 

Comment 

Direct benefits  

is 
for 

clean  energy 
businesses, 
which 
crucial 
long-term 
investment 
and 
development 
in the sector.  

y 
and 
predictability 

better 
coordination 
and 
cooperation 
among 
different 
national 
authorities  

higher 
coherence  of 
planning and 
reporting 
timelines 
and 
procedures 

better-
established 
processes, 

September, 2024 

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Overview of costs and benefits identified in the evaluation 

Citizens/Consumers  

Businesses 

Administrations 

European  Commission’s 
services 

Quantitative   Comment 

Quantitative   Comment 

Quantitativ
e 

Comment  

Quantitativ
e 

Comment 

policies  and 
procedures 

on 

Effects 
administrati
ve 
are 
uncertain 

burden 

‘learning 
curve’ 
component 
acknowledge
d  by 
the 
stakeholders 
(especially 
national 
authorities), 
so  that  it  is 
expected 
the 
that 
burden  will 
lower 
over 
time 

September, 2024 

227 

 
 
 
 
                        
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

Table 36.  Simplification and burden reduction (template) 

 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 

[Other…] _ specify 

Quantitative   Comment 

Quantitative   Comment 

Quantitativ
e 

Comment  

Quantitativ
e 

Comment 

Title664 [Select among:  (i) direct compliance cost savings (for example adjustment cost savings, administrative cost savings, savings from regulatory 
charges); (ii) enforcement cost savings (for example cost savings associated with activities linked to the implementation of an initiative such as monitoring, 
inspections and adjudication/litigation); (iii)  indirect cost savings (if possible - for example indirect compliance cost savings or other indirect cost savings 
such as transaction cost savings).  

Type: Recurrent (select) 

Not applicable   

Not applicable   

of 

The 
Governance 
Regulation 
has 
streamlined 
some 
aspects 
energy 
policy 
planning and 
reporting, 
but 
number 
Member 
States  also 

a 
of 

664    Each simplification/saving should be included on a separate line.  

September, 2024 

228 

 
 
 
 
 
               
 
 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

to 

point 
increased 
administrati
ve  burdens, 
while  others 
seem 
to 
have  noticed 
actual 
in 
savings 
time  and/or 
resources.  It 
is  difficult  to 
disentangle 
the workload 
created 
by 
the 
Governance 
Regulation 
from aspects 
more  related 
to 
the 
organisation
al  aspects  of 
the  national 
administrati
ons 
(including 
limited 
coordination 
between 
those 
in 
involved 
the reporting 
obligations, 
the evolution 
of 
the 
legislative 
framework 

September, 2024 

229 

 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

the 

and 
additional 
workload 
imposed  by 
the 
Regulation  – 
if 
– 
any 
compared  to 
reporting 
obligations 
that  would 
be  in  place 
anyway).  

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

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 objectives665. 

Citizens/Consumers/Workers 

Businesses 

Administrations 

[Other…] _ specify 

Quantitative   Comment 

Quantitative   Comment 

Quantitati
ve 

Comment   Quantitati

Comment 

ve 

Description:… 

Type:  Recurrent (select) 

Not applicable   

Not 
applicable 

665    This assessment is without prejudice to a possible future Impact Assessment. 

for 

Costs 
annual 
reporting 
(cumulati

Synchronizat
ion 
obligations 
like  Directive 

with 

for 

Costs 
annual 
reporting 
(art.  26) 

September, 2024 

230 

 
 
 
 
 
 
 
 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

of 

the 

ve) 
represent 
about 
22% 
the 
recurrent 
costs 
incurred 
by 
Member 
States  to 
comply 
with 
Governan
ce 
Regulatio
n  on  a 
yearly 
basis. 
Reducing 
the 
frequency 
this 
of 
obligation 
(e.g. 
every  two 
years 
instead  of 
every 
year) 
would 
reduce  by 
the 
half 
costs 
of 
the 
obligation, 
by 
and 
the 
12% 

(EU) 
2016/2284 
on 
the 
reduction  of 
national 
emissions  of 
certain 
atmospheric 
pollutants, 
and  National 
Air  Pollution 
Control 
Programmes 
the 
under 
NEC 
Directive 

UN 

GHG 

Alignment  of 
frameworks 
on 
emissions 
with 
obligations: 
both  include 
biennial 
reporting 
obligations, 
but  each  in 
different year 
(even  years 
for 
UNFCCC/BTR 
- 
Biennial 
Transparenc
y Report, and 
odd years for 
NECPR 

EU 

represent 
about 
10.4%  of 
the 
recurrent 
costs 
incurred 
by 
institution
s 
to 
implement 
the 
Governanc
e 
Regulation 
on 
a 
yearly 
basis. 
Reducing 
the 
frequency 
of 
this 
obligation 
(e.g. 
every  two 
years 
instead  of 
every 
year) 
would 
reduce  by 
the 
half 
costs 
of 
the 
obligation, 
and by 6% 
the annual 
for 
costs 

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EU 
institution
s 

annual 
costs 
Member 
States  

for 

.  

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Final Evaluation Report 

ANNEX 4. EVALUATION FRAMEWORK 

This  annex  presents  the  evaluation  framework,  which  provides  the  foundation  for  the 
evaluation and ensures that each of the five evaluation criteria covered by this assignment 
(effectiveness,  relevance,  efficiency,  coherence,  and  EU  added  value)  are  properly 
addressed  in  a  systematic  and  transparent  way.  For  each  criterion,  the  evaluation 
framework presents the following elements:  

  Evaluation questions and sub-questions that indicate the main elements that 
will  be  analysed,  presented  by  evaluation  criteria  and  in  accordance  with  the 
evaluation questions listed in the ToR; 

  Judgement criteria, which summarise the initial assumptions which will be tested 
throughout the  evaluation, further indicating the elements that will be covered in 
the answers to the evaluation questions; 

  Examples of quantitative, qualitative, and opinion-based indicators,  which 
provide an insight into the types of data and evidence that will be used to inform 
the  assessment  of  the  judgement  criteria  and,  ultimately,  the  answers  to  the 
evaluation questions. The list of indicators provided in the table is preliminary and 
non-exhaustive. For some indicators, data may not be available, and the indicators 
may  thus  need  to  be  excluded  at  a  later  stage.  In  other  cases,  there  may  be 
additional  indicators  that  have  not  yet  been  identified  and  that  will  only  emerge 
through the desk research and consultation as the study progresses; and 

  Data  sources,  which  provide  the  methodological  sources  expected  to  produce 

relevant evidence. 

This evaluation framework covers all the topics considered in the questions provided in the 
ToR.  However,  in  collaboration  with  DG  ENER  and  DG  CLIMA,  we  have  integrated  the 
evaluation  questions  and/or  grouped  and  rearranged  them  to  ensure  a  streamlined 
approach to the evaluation. This evaluation framework was approved by DG ENER and DG 
CLIMA on 25 July 2023 and forms the basis of the evaluation. 

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Analysis 
cross-
reference  

 

  See 

section 
5.111 

Table 37.  Evaluation Framework of the evaluation  

Evaluation Questions &  

Judgement criteria 

Sub-questions 

Indicators 
requirements 

and 

information 

Data sources 

 

 

 

EFFECTIVENESS  

To what extent has the Regulation effectively achieved its key objectives, across the five dimensions of the Energy Union (energy security; 
internal energy market; energy efficiency; decarbonisation; research, innovation and competitiveness) 

led 

the 

EQ1  -  To  what  extent  has  the 
Governance  Regulation 
to 
increased 
increased 
quality, 
timeliness and increased (public) 
reported 
of 
accessibility 
the  Energy 
information  across 
Union’s 
and 
regarding all aspects of relevance to 
the  Regulation’s  objectives,  notably 
in  terms  of  national  Energy  and 
Climate  Plans  (NECPs),  Long-Term 
Strategies,  and  annual  and  biennial 
reports? 

dimensions 

five 

plans, 

  EQ1.1  -  To  what  extent  did  the 
Governance  Regulation  contribute  to 
improved 
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? 

reports 

  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? 

  The 

information 
in 

is  made 
accurate, 

an 

available 
complete and timely manner 
  Member  States  fulfilled  their 
current  planning  and  reporting 
obligations 
in  an  adequate 
manner  in  terms  of  timeliness, 
consistency, 
completeness, 
comparability, 
coherence, 
transparency and accuracy. 

 

Indicators  used  in  the  reports 
effectively 
comparably 
and 
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  Governance  Regulation  led 
to  increased  transparency  and 
public  accessibility  of  reported 
information. 

  Quantitative indicators 

  Number  of  documents 

/ 

reports 

submitted on time to the Commission 
  Number  of  views  /  downloads  of  the 
publicly 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 
(take  up 
the  process 
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 

  Legal mapping 
  Desk 

research, 
including desk review 
of EC assessments of 
draft  /  final  NECPs, 
and 
wider 
of 
stakeholders 
assessments (reports 
from ECA, academics 
or  think  tanks)  on 
for 
potential  scope 
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 

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Evaluation Questions &  

Judgement criteria 

Sub-questions 

Indicators 
requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

followed 

To  what  extent  have  the  Member 
guidance 
States 
documents 
the 
provided 
Commission?   What  problems  have 
been observed and why?  

the 

by 

Commission 

  EQ1.6  -  To  what  extent  has  the 
dedicated technical support funded by 
the 
facilitated 
the 
planning and reporting process? 
  EQ1.7  -  To  what  extent  has  the 
Governance 
to 
increased  transparency  and  public 
accessibility of reported information? 

Regulation 

led 

  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 

relevant 
stakeholders 
or 
expanding  coverage  /  timeliness  / 
and 
transparency 
feasibility of addressing these needs 

accessibility 

improving 

for 

/ 

  Answer 

The  Governance  Regulation  has  led  to  increased  quality  of  the  reported  information  across  the  Energy  Union’s  five  dimensions  and  regarding  all  aspects  of  relevance  to  the 
Regulation’s objectives.  

Quality of reported information 

While  the Governance  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 divergent approaches with this potentially influencing the nature of the collected information. The Governance 
Regulation has effectively contributed to an improved accuracy of the available data around the five dimensions to be covered as per Article 15(4) of the Governance Regulation in 
LTSs. Notwithstanding this the evaluation found that divergent national planning traditions negatively impacted the completeness of the LTSs, with Member States sometimes not 
reporting all the mandatory content as per 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 the enforcement of Articles 17 to 25 proved effective only to some extent, with significant data gaps still remaining. Concerning the 
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 deteriorated. 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 timeliness of the submission of the draft NECPs was not always ensured. Nevertheless, it is unclear whether this problem is directly linked to the Governance Regulation or 
whether it results from practices and/or procedural bottlenecks occurring at a Member State level. There were 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 Governance Regulation and the sequencing of the planning 
and reporting obligations (e.g., NECPs deadline prior the LTSs one). Notwithstanding this, there is no evidence that the Governance Regulation, as such, was ineffective in ensuring 
that LTSs were submitted in a timely manner. Enforcement and administrative burdens seem to have caused the delayed submission of LTSs. The biennial progress reports and 

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Judgement criteria 

Sub-questions 

Indicators 
requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

their follow up (NECPRs and reporting obligations stemming from Article 17 of the Governance Regulation) were submitted either on time or with a small delay, with 
this not impacting the effectiveness of the Governance Regulation.  

The timeliness of information on PaMs remained stable between 2017 and 2019, it improved in 2021, and then deteriorated in 2023. Information reported on projections of 
anthropogenic greenhouse gas emissions by sources and removals by sinks improved in 2019 if compared to 2017, while it deteriorated in 2021. Notwithstanding this, the 
evaluation does not find a lack of effectiveness that can be attributed to the Governance Regulation.  

(Public) accessibility of reported information  

  The  Governance  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 Governance 
Regulation as such or, which is more likely, to implementation issues and/or different national traditions across the EU.  

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  EQ2  -  What  difference  has  the 
Governance  Regulation  made  in 
terms  of  promoting  better 
planning 
and 
implementation  of 
effective 
plans and reports? 

processes 

  EQ2.1 

-  What 

qualitative 

or 
quantitative  evidence  is  there  that 
Member States make adequate 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?   

that 

  EQ2.3  -  Is 
there  qualitative  or 
the 
evidence 
quantitative 
Governance  Regulation  has  increased 
the  effectiveness  of  Member  States’ 
national  planning  and  has  resulted  in 
more  substantial  implementation  of 
climate,  energy  policies  and  other 
and 
(reforms 
policies 
relevant 
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 
Governance  Regulation  being 
used at the MS and EU level 

  There 

is 

of 
Governance  Regulation  tools  at 
the national level 

ownership 

  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 
Governance  Regulation  can  be 
identified 

  There  is  evidence  of  progress 
with  measures  (reforms  and 
investment) 

reinforced 

  There is evidence to suggest that 
the  Governance  Regulation 
accelerated, 
or 
promoted  measures  (reforms 
and investment) in certain areas  
  Barriers  to  the  implementation 
of  NECPs 
adequately 
are 
monitored  and  actions  are 
planned / undertaken to correct 
them as appropriate. 

See  section 
5.1.1.2 

  Literature  review  of 
actual 
progress 
towards  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 
interviews 

level 

 

Interviews  with  MS 
authorities 

  Targeted 

surveys 

with MS authorities 
  Workshop  on  draft 
evaluation results 
  EU level interviews  
 
International 
interviews 

level 

 

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  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  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 
and 
been 
for 
communication  purposes  by 
the 
Commission 

policy 

used 

  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; 

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ii)  EU  targets  and  iii)  international 
commitments 

  Overall 

implementation 

status  of 
planned  measures 
the 
integrated national energy and climate 
share  of 
reports  e.g. 
progress 
measures that are on track  

as  per 

  Qualitative indicators 

  Extent to which inter-ministerial teams 
are  set  up  and  work  consistently 
towards  the  implementation,  update 
and  monitoring  of  the  national  energy 
and climate policy 

  Qualitative  assessment  of  overall 
progress  made  with  relevant  Policies 
and Measures  

  Stakeholders’  and  experts’  views  on 
the 
the 
Governance  Regulation  to  progress 
made 

contribution  of 

specific 

 

Further information requirements 
  Any 

constraining 

the 
factors 
NECPs 
implementation 
(identification  of  barriers 
the 
deployment  of  some  measures)  and 
planned 
/  mitigating 
measures 

corrective 

to 

of 

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Evaluation Questions &  

Judgement criteria 

Sub-questions 

Answer 

Planning processes and implementation of plans and reports 

Indicators 
requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

The  Governance  Regulation  has  been  effective  in  promoting  better  planning  processes  and  effective  implementation  of  plans  and  reports.  For  instance,  the  Governance 
Regulation  helped  streamline  the  planning  processes  across  the  energy  and  climate  domains,  with  an  increased  cooperation  among  different  ministries/authorities  at 
national  level.  Nevertheless,  in  several  Member  States,  NECPs  are  not  particularly  relevant  for  national  planning  processes  and  are  mainly  developed  to  meet  an  EU 
obligation. Similarly, LTSs are partly outdated and do not necessarily serve as the basis for NECP development.   

  Quantitative indicators 

  Number  of 

times 

the  gap 

filling 
mechanism  has  been  used  (e.g. 
number of Union 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 in order to cover the gap where 
appropriate  

Further information requirements 
  Stakeholders’  and  experts’  view  on 
(anticipated) effectiveness of the tools 
and potential scope for improvement 

  The  EU  has  tools  to  deploy  in 
or 
ambition 
are 

gaps 
deficits 

case 
implementation 
detected. 

  These 

tools  are  effectively 

deployed when needed 

  These  tools  are  effective  when 

deployed. 

  The 

ambition 

gap-gilling 
mechanisms are fit for purpose, 
they prompt MS  to  act  to cover 
the gap (when needed). 

  Need  to  provide  an  explanation 
of  how  gap  will  be  covered  in 
progress 
report  acts  as  a 
powerful incentive. 

  Potential  gap  filling  measures 

work as planned. 

  RES  financing  mechanism  is  fit 
for  adequately  fulfilling  its  gap 
filling function 

the 
EQ3  -  How  effective  has 
Governance  Regulation  been 
in 
responding  to  any  ambition  or 
deficit 
implementation 
(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 timely 
and adequately? 

  EQ3.3  - Have the ambition gap-filling 
mechanisms under Articles 31  and 32 
of 
used 
effectively? 

the  Regulation 

been 

Answer 

Enforcement  

September, 2024 

See  Section 
5.1.1.3 

  Legal mapping of the 
available  tools  and 
desk  review  of  their 
including 
use 
statistics  /  mapping 
on  the  use  of  the 
Union-level 
measures, 
gap 
filling  mechanisms 
for RES, EE and GHG 
goals;  mapping  of 
Commission 
recommendations 
to MS  and  follow  up 
to 
EC 
recommendations 

, 

 

International 
interviews 

level 

  EU level interviews 
  MS level interviews 
  Targeted 

surveys 

with MS authorities 

  Case studies 
  Workshop  on  draft 
evaluation results 

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Judgement criteria 

Sub-questions 

Indicators 
requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

Evidence shows that the main hindering factor when it comes to implementation deficits is the fact that the enforcement mechanism is mainly based on recommendations, 
which  are  not  legally  binding.  The  Governance  Regulation  has  also  partly  stimulated  regional  cooperation  among  Member  States.  However,  the  potential  of  regional 
cooperation has yet to be fully exploited.  

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

  There  has  been 

investment 
technologies 

in 

increased 
sustainable 

  The role and contribution of the 

NECPs can be identified 

  EQ4.1  -  Is 

there  qualitative  or 
that  NECPs 
quantitative  evidence 
created a more stable and predictable 
regulatory 
create 
framework 
investment  certainty  and  stimulate 
public and private energy and climate 
spending and investments? 

to 

  EQ4.2  -  To  what  extent  has  the 
Regulation  helped  MS  to  take  full 
advantage 
for 
economic  development, 
investment 
stimulation,  job  creation  and  social 
cohesion? 

opportunities 

of 

  EQ4.3  -  Which  elements  of  the 
such 

(still)  hindered 

framework 
investor certainty?  

  EQ4.4  -To  what  extent  has  the 
Regulation 
reliable 
resulted 
information  on  investment  needs  and 
sources  of  private  and  public 
finance? What bottlenecks can be 
identified in this regard? 

in 

See  section 
5.1.1.4 

  Desk research 
  EU  level  interviews 
(with  representatives 
investor 
of 
community 
/ 
industry) 

the 

  MS  level  interviews 
(with  representatives 
investor 
of 
community 
/ 
industry) 

the 

  Targeted  survey  of 
energy  industry  and 
of  energy-intensive 
industries 
  Case studies 

  Quantitative indicators 

 

Investment  needs  at  Energy  Union 
priority  level  or  sector  level  in  NECPs 
for 2021-2030 

  Source of financing public/private at EU 
and  national  level  in  NECPs  for  2021-
2030 

 

levels 

Investment 
sustainable 
technologies  in  Member  States  and  at 
EU  level  (trends  before  /  after  the 
Governance Regulation) 

in 

  Funds incl. EU funds being deployed to 
support the ambition of the NECPs 

  Awareness 

levels  of 

investor 
community  /  industry  about  NECPs  in 
survey results 

the 

  Share  of  respondents  assessing  the 
contribution  of  NECPs  to  investment 
levels as essential / anecdotal 

 

  Qualitative indicators 

  Stakeholder  views  on  contribution  of 
levels 

investment 

NECPs 
to 
(qualitative) 

 

Further information requirements 
  Examples  /  instances  where  NECPs 
were used as capital raising plan 

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Judgement criteria 

Sub-questions 

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Indicators 
requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

  Any  factors  still  hindering  investor 

certainty 

Stimulating spending and investment and ensuring regional cooperation  

There was limited feedback on the Governance 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 industry stakeholders consulted as part 
of the data collection. Overall, interviewed stakeholders were not always knowledgeable about all the objectives, obligations, and outputs stemming from the Governance 
Regulation, with many of them mainly providing feedback on the NECPs and NLTSs. Additionally, consulted stakeholders were not always aware of the situation before 
the entry into force of the Governance Regulation or could not link specific trends (e.g., on investments, on regional cooperation) to the entry into force of the Governance 
Regulation 

EQ5  -  How  successful  has  the 
Regulation 
ensuring 
in 
regional cooperation? 

been 

  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 
opportunity 
other MS draft NECPs 

adequate 
to  comment  on 

had 

  The  Commission  has  facilitated 
cooperation  between  the  MS  as 
regards  the preparation  of  their 
NECP 

 

 

 

  Quantitative indicators 

  Number  of  times  MS  have  cooperated 
bilaterally  or  multilaterally  with  other 
MS in preparation of their NECPs   

 

  Qualitative indicators 

  Level  of 

regional  cooperation 

in 
drawing  up  the  plan,  as  reported  by 
MSs in their NECPs 

  Steps 

taken 

toward 

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 

September, 2024 

  Desk 

research 
including  review  of 
regional  cooperation 
activities  undertaken 
as  summarised 
in 
NECPs,  review  of  the 
outcomes 
the 
NECPlatform project  

of 

  EU level interviews 
  Targeted  surveys  of 
MS authorities 
  MS level interviews  
  Case studies 
  Workshop  on  draft 
evaluation results 

See  section 
5.1.1.5 

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Evaluation Questions &  

Judgement criteria 

Sub-questions 

Indicators 
requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

Consulted stakeholders were not always aware of the situation before the entry into force of the Governance Regulation or could not link specific trends (e.g., on investments, 
on regional cooperation) to the entry into force of the Governance 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 LTSs/other reporting obligations is more limited and hence a lot is based on the European 
Commission reports/assessments 

  Appropriate  multilevel  climate 
and  energy  dialogues  were  set 
up 

  Regional  cooperation  activities 

were conducted. 

  Appropriate  public consultations 

were conducted  

  EQ6.    How  successful  has  the 
in  ensuring 
and 
dialogue 

Regulation  been 
adequate  multi-level 
multi-stakeholder 
and consultation?  

 
  EQ6.1  -  How  successful  has  the 
Regulation  been  in  ensuring  Member 
States  set  up  adequate  multilevel 
climate and energy dialogues involving 
sub-national  authorities  and  other 
relevant actors in national energy and 
climate policy-making?  

  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?  

  Quantitative indicators 

  Existence  of  a  permanent  structure 
acting  as  multi-level  climate  and 
energy  dialogue,  with  participation  of 
sub-national  authorities  and  other 
relevant stakeholders.  

  Extent  to  which  such  platform  is  used 
consistently 
the 
implementation of the NECPs, including 
its mandatory reporting. 

throughout 

  Extent  to  which  activities  were  in  line 
with the Aarhus Convention (e.g. wide 
consultations, open for sufficiently long 
periods with real possibilities to provide 
inputs) 

  Number  of  MS  where  a  public 
consultation  on  the  draft  NECP  was 
conducted 

  Extent  to  which  national  stakeholders 
feel they were adequately consulted on 
MS draft NECPs 

 

Further information requirements 
  Any  factors  facilitating  /  constraining 

regional cooperation  

Answer 

Ensuring adequate multi-level and multi-stakeholder dialogue and consultation 

 See section 
5.1.1.6 

  Desk 

research 
including  review  of 
consultation  
activities  undertaken 
as  summarised 
in 
NECPs,  review  of  the 
the 
outcomes 
NECPlatform project  

of 

  EU level interviews 
  Targeted  surveys  of 
MS authorities 
  MS  level  interviews 
interviews 
including 
sub-national 
of 
authorities 
and 
relevant stakeholders 
  Targeted interviews  
  Case studies 
  Workshop  on  draft 
evaluation results 

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Evaluation Questions &  

Judgement criteria 

Sub-questions 

Indicators 
requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

The available evidence shows that although the introduction of Articles 10 and 11 of the Governance Regulation is perceived as a significant step forward, the Governance 
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? 

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

coherence 

 
  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 
as 
environmental protection)?   

policy 

areas 

such 

planning 

  EQ7.2  -  Is  the  (already  rationalised) 
administrative  burden  of  Member 
States' 
reporting 
obligations  proportionate  to  the  need 
for  a  harmonised  and 
integrated 
planning and reporting process across 
the  five  dimensions  of  the  Energy 
Union?  

and 

  EQ7.3  -  Do  the  benefits  of  this 
harmonised and integrated process (in 
terms  of  improved  policy  coherence, 
regional 
impact 
cooperation, 
assessment,  etc)  justify  the  higher 
individual 
complexity  compared  to 
processes? 

  The  streamlining  of  the  energy 
and  climate  planning,  reporting 
and monitoring obligations led to 
cost 
reduced 
administrative  burden  at  both 
EU and MS level. 

savings 

/ 

  Costs and administrative burden 
are assessed to be and seen as 
proportionate. 

  The  rationalised  administrative 
burden  for  integrated  planning 
and reporting process is justified 
when  considering  the  benefits 
(in  terms  of  improved  policy 
coherence, regional cooperation, 
impact assessment, etc) 

  Quantitative indicators 

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

the 

  Number 

/  share  of 

respondents 
reporting favourable evolution of costs 
since  the  entry  into  force  of  the 
Regulation,  and  comparison  of  results 
with  expectations  when  adopting  the 
Governance 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 

 

 Section 

5.1.2.1 

  Desk 

research, 
including  data  on 
and 
enforcement 
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 
as 
well 
administrative 
benefits) 

  Targeted  survey  of 
MS authorities  

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Evaluation Questions &  

Judgement criteria 

Sub-questions 

  EQ7.4  -  What  factors  most  influence 
the costs and administrative burden of 
Member States' planning and reporting 
obligations?  Is  there  qualitative  or 
quantitative evidence allowing to weigh 
the impact of each factor on costs? 

 

Indicators 
requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

  Number  /  share  of  reporting  and 
the 
planning 
allocated  time  to  be  sufficient  to 
perform their duties adequately 

teams  who  deem 

  Workshop  on  draft 
evaluation results 

  Qualitative indicators 

  Extent  to  which  the  expected  benefits 
are  considered  to  be  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 
impact  on 
framework, 
investor confidence) 

  Extent  to  which  the  cost/  benefits  are 
considered  to  be  balanced  across  the 
five dimensions 

Answer 
The efficiency analysis shows mixed results: it has streamlined some aspects of energy policy planning and reporting, but a number of Member States also point to increased 
administrative burdens, while others seem to have noticed actual savings in time and/or resources. However, it is difficult to disentangle the workload created by the 
Governance Regulation from aspects more related to the organisational aspects of the national administrations concerned (including limited coordination between those 
involved in the reporting obligations, the evolution of 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 Governance Regulation include the 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. The benefits of the Governance 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 when not fully materialised yet, many stakeholders (especially within national 
authorities) considered that the Governance Regulation is pushing national administrations to work more closely and establish coordination procedures when they did not 
exist before. There is also a ‘learning curve’ component acknowledged by the stakeholders (especially national authorities): while the initial reporting cycles have been 
more complex and burdensome, it is realised that the whole process will become simpler (and thus less burdensome) over time, the more reporting are files and assessed, 
the more clarity is made over 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 

  Quantitative indicators 

  Administrative  and  financial  benefits 
for Member States and the Commission 

  Desk research 
  MS level interviews 
  Case studies 

 See section 
5.1.2.2 

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Judgement criteria 

Sub-questions 

Indicators 
requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

templates  decrease 

  EQ8.1 - Regarding progress reporting, 
to what extent does the availability of 
an electronic reporting platform and/or 
common 
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 
of 
collecting,  organising,  and  analysing 
large  sets  of  data  (big  data  analytics, 
machine-to-machine reporting)? 

processes 

and 

burden and costs for the Member 
States.  

from 

resulting 
reporting  via  an 
electronic  platform  instead  of  textual 
format 

  Targeted  survey  of 
MS authorities 

 

(cost 

costs 

Further information requirements 
  Stakeholder views on main cost drivers 
–  distinguishing  between  one-off 
for 
implementation 
IT 
developing  or  adapting 
of 
infrastructure, 
organisational changes / establishment 
of  processes,  cost  for  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) 

introduction 

the 

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 that the prescribed 5-year timeframe for strategic decisions in the energy sector often falls short, as significant shifts in energy systems 
typically  require  longer-term planning,  the  alignment of  timetables  for  various  tasks, such  as preparing  the  NECPs and  NEC  reporting,  resulting  in  a  lack of  adequate 
incorporation of  lessons  learned  from previous planning  cycles,  and  the  overlapping of draft  NECP  update  and  NECPR  in 2023.  Among other  EU obligations,  the  main 
difficulties included the synchronization 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, 
The most critical one seems to be that both frameworks on GHG emissions include biennial reporting obligations, but each in different year (even years for UNFCCC/BTR 
- Biennial Transparency Report, and odd years for NECPR) (more details are provided in section 5.1.3).  
Qualitative indicators 
  Extent to which the e-platform fulfils all 
of  its  functions  repository  for  plans, 
reports and strategies tracker function 
(allowing  to  follow  live  the  latest 
developments in the implementation of 
the  NECPs)  access 
to  data  and 
underlying  assumptions  in  a  user-

the 
functions  of  the  e-
platform  
  Legal mapping 
  EU  level  interviews 
international 
and 
level 
interviews 
(feedback from those 

  The current set up is suitable (to 
to 
facilitate 
facilitate 
to 
information)  and  reflects  latest 
digital developments. 

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

  There  is  consistency  between 
different planning, reporting and 
in 
monitoring 

communication, 
access 
public 

 See section 
5.1.2.3 

  Mapping 

contributed 

obligations 

of 

 

 

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Evaluation Questions &  

Judgement criteria 

Sub-questions 

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

  EQ9.2 - Is there evidence of red tape 
due  to  overlaps  with  other  EU  or 
national 
reporting 
procedures?  

planning 

and 

  EQ9.3  -  To  what  extent  have  the 
planning and reporting processes taken 
into consideration other reporting and 
planning  obligations  (e.g.  JTM,  RRF, 
etc.)  in  order  to  avoid  potential  peak 
reporting and planning periods? 

 

to 

different  fields  that  is  directly 
the  energy  and 
related 
climate  (in  terms  of  timing  / 
periodicity/  scope)  –  including 
synchronicity  with 
the  Paris 
Agreement  / other  international 
obligations  

  There  is  no  scope  for  further 
consolidating  obligations  within 
Governance  and  between  the 
Governance  Regulation 
and 
other related EU acquis 

Indicators 
requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

receiving 
information) 

the 

  MS  level  interviews 
(feedback from those 
producing 
the 
information) 

  Targeted  survey  of 
MS authorities 
  Case studies  
  Workshop  on  draft 
evaluation results 

(e.g. 

friendly  manner 
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 

for 

Further information requirements 
  Room 

improvement,  any  best 
practice  example  at  MS  (solutions  for 
streamlining and digital processing) 
  Main  factors  /  obligations,  within  or 
beyond  the  scope  of  the  Governance 
Regulation,  adding  to  administrative 
burden  and/or  undermining  policy 
coherence (e.g. new initiatives adopted 
since  the  entry  into  force  of  the 
Governance  Regulation,  international 
obligations,  domestic  planning  and 
reporting procedures) 

  Potential  for  further  streamlining  of 
obligations  (e.g.  better  alignment  of 
the  periodicity  of  planning,  reporting 
obligations  with 
and  monitoring 
obligations  at  the  international  level, 
for  streamlining  parallel 
potential 
domestic  planning  and 
reporting 
procedures) 

Answer 

Mixed views were also reported about the benefits brought by the use of common templates and platforms. Indeed, the number of responding national authorities who believe 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, is the same of those who have an opposite 
view. Although the majority of responding national authorities shared 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 on the platforms, since these are designed following different criteria than the templates provided in the Regulation. 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 interlinks between the platforms. The 

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Evaluation Questions &  

Judgement criteria 

Sub-questions 

Indicators 
requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

reasons for cost/ and burden decrease included the fact that the platforms give the possibility to know what information and data should be collected and submitted, they help to 
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 possibility of errors. The existence of two separated platforms has garnered some criticism from many stakeholders, in particular because of the poor interlinkages 
between the two, including the formats. However, some stakeholders appreciated the existence of the 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? 

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 
reporting  and 
different  planning, 
monitoring  obligations  under 
the 
Governance  Regulation  coherent  with 
one another? 

  Domestic,  EU  and  international 
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-
border  considerations  in  their 
revised NECPs 

  Synergies,  potential  trade-offs 
and spillovers across climate and 
energy  policy  areas  are  better 
addressed. 

 

  Quantitative indicators 

  Number 

of 

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

climate 

 

  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 
including  no  mismatch 
consistent 
between 
of 
definitions, 
between 
targets / planned measures, alignment 
between measures planned / measures 
the 
financed 
different obligations 

timely  alignment  of 

consistency 

consistency 

targets, 

 

  Review  of 

targets, 
plans  and  policies  to 
check  alignment  and 
consistencies 

 See section 
5.1.3.1 

  Review 

of 

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

  Review 

of 

EU 
and 

assessments 
international 
(UNFCCC/ 
Paris 
Agreement) reviews   

of 

the 
climate 

  Review 
national 
governance 
framework in place in 
MS  

 

International 
interviews 

level 

  EU level interviews 
  MS level interviews 
  Case studies 
  Workshop  on  draft 
evaluation results 

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Evaluation Questions &  

Judgement criteria 

Sub-questions 

Indicators 
requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

  Extent to which adequate processes 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 Governance 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 Governance 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 Governance Regulation in December 2018.  

  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-off  and  synergies  in  their  draft, 
final and revised NECPs. 

  Qualitative indicators 

  Extent to which potential incoherences 

are minimised  

 

international 

EQ11  - To  what  extent 
is  the 
Regulation  coherent  with  other  EU 
and 
obligations 
(external coherence)? 
  EQ11.1  -  To  what  extent  is  the 
Regulation coherent notably with: 
  Obligations  from  other  energy  and 
climate  EU  acquis,  such  as  those 
stemming  from  the  European  Climate 
Law,  and  other  relevant  parts  of  the 
European Green Deal, Fit For 55?  

 

 

including 
International  obligations, 
from  the  Paris  Agreement  and  its 
enhanced 
framework, 
transparency 
the  Sustainable  Development  Goals, 
the  Aarhus  Convention  and  other 
relevant international conventions and 
for a (e.g. G7, G20)?  

  Other relevant EU policy fields? 

  Legal 

mapping 
including  review  of 
different 
the 
provisions  stemming 
from 
the  different 
legal  bases  and  the 
areas  of  potential 
incoherence  
  Desk research 
 
International 
interviews 

level 

  EU level interviews 
  MS level interviews 
  Case studies 
  Workshop  on  draft 
evaluation results 

 See section 
5.1.3.2 

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Evaluation Questions &  

Judgement criteria 

Sub-questions 

  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? 

Indicators 
requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

Answer  
Issues on external coherence are mostly related to the fact that several EU-level instruments have been introduced and/or updated after 2018,  notably the 
various policies developed  under  the  European Green  Deal  as well  as  different reporting  timelines  compared  to  the UNFCCC reporting  cycle,  and that the timing of 
different  reporting/planning  obligations  are  not  always  aligned.  For  instance,  the  Energy  Efficiency  Directive  (EED)  recast  includes  many  new  elements  for  a 
stronger governance that are not currently incorporated nor streamlined into the Governance Regulation, Similarly, with the Renewable Energy Directive (RED) revision, 
new elements were introduced- including a binding EU target of 42.5 % renewable energy, with an additional non-binding top-up of 2.5% - which are not reflected in the 
Governance Regulation 

 

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  Governance  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 Governance Regulation 

Answer 

September, 2024 

 

 See section 
5.2.1.1 

  Desk research 
  EU level interviews 
  MS level interviews 
  Case studies 
  Workshop  on  draft 
evaluation results 

  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 Governance 
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  Governance 
Regulation 

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Evaluation Questions &  

Judgement criteria 

Sub-questions 

Indicators 
requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

The EU added value of the Governance 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 also depended on national processes that preceded the Governance Regulation. The Governance 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 
reporting 
current  planning  and 
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 
by 
stakeholders. 

assessed 

as 

  Extent 

to  which 

the  Governance 
Regulation 
additional 
makes 
information  accessible  or  available, 
provides information that would not be 
available  from  other  sources  by  other 
by 
regulations, 
stakeholders 

assessed 

as 

See  section 
5.2.1.2 

  Legal  mapping  of 
obligations  and  their 
rationale 
  Desk research 
  EU level interviews 
  MS level interviews 
  Survey 

MS 

of 

authorities 
  Case studies 
  Workshop  on  draft 
evaluation results 

Answer 

The  planning  and  reporting  obligations  set  out  in  the  Governance  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 do so themselves and by requesting data on indicators that certain Member States may not 
have been reporting on or collecting 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 through assessment 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  Governance  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  for  a  wider  set  of 
stakeholders. 

  Qualitative indicators 

  Extent 

to  which 

the  Governance 
Regulation  is  seen  as  providing  added 
value 
transparency  and 
predictability of Member States’ energy 
and climate policies 

the 

for 

 

See  section 
5.2.1.3 

  Desk research 
 
International 
interviews 

level 

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

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Evaluation Questions &  

Judgement criteria 

Sub-questions 

Indicators 
requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

  MS  level  interviews 
wider 
including 
stakeholders’  views 
Survey 
MS 
authorities 
  Case studies 
  Workshop  on  draft 
evaluation results 

of 

Answer 

While the Governance Regulation had a positive effect on 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.  

  The  Governance  Regulation 
provides  adequate  mechanisms 
the  MS  and  EU 
to  hold 
accountable for their obligations 
under 
Governance 
Regulation. 

the 

  The  Governance  Regulation 
supports access to justice. 

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 
Governance  Regulation enabled public 
and private actors to hold MS and the 
EU  accountable  for  their  obligations 
under the Governance 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? 

  Qualitative indicators 

  Extent 

to  which 

the  Governance 
Regulation  is  seen  as  providing  added 
value 
enabling 
accountability in relation to energy and 
climate policies. 

terms 

of 

in 

  Extent 

to  which 

the  Governance 
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  Governance  Regulation 
are 
enforceable by the public  

 

 

Further information requirements 
  Examples 

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

See  section 
5.2.1.4 

  Desk research 
 
International 
interviews 

level 

  EU  level  interviews 
including 
wider 
stakeholders’  views 
from 
views 
(e.g. 
representatives  from 
private  sector  /  civil 
society /  

  MS  level  interviews 
wider 

including 
stakeholders’ views  

  Survey 

of 

MS 

authorities 
  Case studies 
  Workshop  on  draft 
evaluation results 

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Answer 

Indicators 
requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

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 a number of 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 
Governance Regulation still  relevant 
in 
legislative 
of 
view 
developments666 ?  

  EQ16.1 

-  Are 

there  planning, 
reporting,  and  monitoring  obligations 
missing 
Governance 
Regulation in view of recent legislative 
developments? 

from 

the 

  EQ16.2 - Are there planning, reporting 
and  monitoring  obligations  under  the 
Governance  Regulation 
that  have 
become obsolete? 

 

 

 

 

  Existing planning, reporting and 
monitoring  obligations  continue 
to be 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 
the 
Governance Regulation. 

force 

into 

of 

 

  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 
reporting  and 
that 
the 
of 
monitoring 
obligations 
Governance  Regulation 
still 
are 
relevant  in  view  of  recent  legislative 
developments. 

the  planning, 

 

 

 See section 
5.3.1.1 

  Legal mapping 
  Desk 

research 
including  mapping  of 
final / revised NECPs  

 

International 
interviews 

level 

  EU level interviews 
  MS level interviews 
  Survey 

of 

MS 

authorities 
  Case studies 
  Workshop  on  draft 
evaluation results 

666 (the European Green Deal (EGD) and the relevant follow-up legislation, the European Climate Law (ECL), the Recovery and Resilience Facility (RRF) and RepowerEU, the Green 
Deal Industrial Plan (GDIP), the (planned) Net-Zero Industry Act (NZIA) and the Critical Raw Materials Act (CRMA), the 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 Governance 
Regulation) 

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Evaluation Questions &  

Judgement criteria 

Sub-questions 

Answer 

Indicators 
requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

The evaluation found that Governance 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. It has rather become more relevant given the growing urgency of climate action and the increasingly complex 
needs that Member States' energy and climate policies have to address. As the outlook for climate change and its associated impacts is both worsening and becoming more clear-
cut, the core objective of the Governance Regulation - to enable and support climate action - is more relevant than ever. Since the adoption of the Governance Regulation in 2018, 
the EU energy and climate acquis has undergone important developments, notably in the 'Fit for 55' package.  As a primarily procedural framework that does not itself set 
specific targets, this has not rendered the Governance Regulation obsolete as an instrument. However, certain issues reflected in recent legislation need to be better addressed in 
the "products" adopted under the Governance Regulation, such as the NECPs 

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

to 

 

 

it  provides 

  EQ17.1  -  To  what  extent  is  the 
information 
relevant, 
complete  and  timely  in  the  context  of 
the  current  geo-political  context,  in 
context  of  the  accelerated  energy 
transition (including increasing macro-
economic impact of energy and climate 
policy) 
of 
scientific/technological  progress  and 
innovation?  

view 

and 

in 

the 

  There  are  mechanisms  in  place 
to  ensure  information  produced 
under 
Governance 
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 
required 
information  readily  available  at 
times of crises  

the 

  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 
extent 
to  which 
into  account  new 

guidance  and 
templates 
take 
priorities 

  Extent 

to  which 

required 
information  was  available  during  the 
recent energy crisis 

the 

 See section 
5.3.1.2 

  Legal  mapping  of 
review 

reporting  / 
processes 

  Desk 

research 
including  mapping  of 
final  /  revised  NECPs 
to  

 

International 
interviews 

level 

  EU level interviews 
  MS level interviews 
  Survey 

of 

MS 

authorities 
  Case studies 
  Workshop  on  draft 
evaluation results 

Answer 

The governance mechanisms of the Governance 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. Themes that do not appear to be adequately reflected include climate adaptation and energy sufficiency. This may 
negatively impact the ability of the Governance 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. While lending additional relevance to the Energy Union’s objectives and accelerating clean energy transition it also 
caused a recalibration of immediate policy priorities and highlighted transition challenges.  

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requirements 

and 

information 

Data sources 

Analysis 
cross-
reference  

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

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ANNEX 5. CASE STUDIES  

This annex provides the findings from case studies. As explained already in Annex 1 on the 
methodological approach and limitations, seven case study countries (Belgium, Denmark, 
France,  Germany,  Malta,  Romania,  and  Poland)  were  purposively  selected  for  a  more 
detailed data collection and analysis. The data for the case studies has been collected via 
desk research and a small number of telephone interviews with key stakeholders, including 
national  authorities,  industry  and  NGOs,  in  each  of  the  case  study  Member  States.  The 
information  presented  in  these  case  studies  has  been  used  to  support  the  efficiency 
analysis (information on the costs and benefits of the Governance Regulation) as well as 
other themes of the evaluation including the effectiveness and EU added value of public 
consultation and multilevel climate and energy dialogues, and of regional cooperation. The 
findings  from  the  case  studies  have  also  been  used  in  identifying  lessons  learned  and 
recommendations. The following subsections present the case study results. . 

A5.1. Case Study - Belgium 

A5.1.1. Background  

Belgium  is  a  federal  constitutional  monarchy  where  decision-making  powers  are  divided 
between  three  levels  of  government:  the  federal  government,  three  language-based 
communities  (Flemish,  French  and  German-speaking)  and  three  regions  (Flanders, 
Brussels  Capital  and  Wallonia).  Legally  they  all  are  equal,  but  have  powers  and 
responsibilities for different fields.”667 Economy, transport, environment, energy, research, 
cities and ‘mixed competences’, exercised both at federal and regional or community level. 
Regions have powers in ‘territory-related’ areas, in a broad sense. They are responsible for 
the  economy,  employment,  agriculture,  water  policy,  housing,  public  works,  energy, 
transport  (with  the  exception  of  the  national  railway),  environment,  town  and  country 
planning, rural revitalisation, nature conservation, among others. They are responsible for 
scientific research and foreign relations in the above-mentioned areas.”668 

In  the  framework  of  reporting  obligations  resulting  from  the  Governance  Regulation, 
several interinstitutional organs are worth mentioning: 

  The  Belgian  Interregional  Environment  Agency  CELINE  (IRCEL  in  Flemish)  is  in 
charge of compiling regional environmental data (incl. GHG emissions) and report it 
at national level; 

  The  National  Climate  Committee  (NCC)  has  a  more  policy-oriented  role,  bringing 
together representatives from ministries of Environment, Climate, Health, etc. with 
representatives from the different regional administrations; 

  The  CONCERE  (Energy  Concertation  between  the  Regions  and  the  State)  is  the 

equivalent of NCC for energy; 

  The Stuurgroep NEKP (steering committee NECP) composed of representatives from 
the NCC and CONCERE. Its role is to coordinate NCC and CONCERE’s works with a 
comprehensive vision of climate and energy actions, from both federal and regional 
perspectives. 

  The  Coordination  Committee  for  International  Environmental  Policy  (CCIEP)  that 
ensures  the  coherence  of  the  international  position  of  the  Belgian  State  and  its 
components during international negotiations. 

Due on the 30th June 2023, Belgium submitted its draft NECP on the 3rd December 2023. 
The document is a compound of four Energy & Climate Plans: one for the federal level and 
one for each of the three regions. As such, each section of the template contains a sub-

667 https://european-union.europa.eu/principles-countries-history/country-profiles/belgium_en 
668 Belgian 8th National Communication and 5th Biennal Report on Climate Change - https://climat.be/doc/nc8-
br5.pdf 

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section for each entity, thus resulting in a longer document than for other countries (752 
pages, against 199 pages for France, for example).  

Due on the 1st January 2020, Belgium submitted its Long-Term Strategy (LTS) on the 2nd 
March 2020. It is composed of a summary of measures at country level, based on the three 
regional  contributions  found  later  in  the  report,  which  in  fact  are  regional  long-term 
strategies. The documents announces that national GES emissions were 79 Mt CO2eq in 
2005 to decrease to 70.9 in 2017. Following its LTS, Belgium expects this number to fall 
at  52.6  Mt  CO2eq  in  2030  and  between  10  and  12  Mt  CO2eq  in  2050,  thus  reducing  its 
emissions by 85% on the period 2005-2050. 

Since the draft NECP update has only been  submitted in December 2023, the European 
Commission has not performed its assessment at the time this case study is written. Also, 
the  interviews  did  not  provide  any  indication  about  the  possible  contents  of  the  NECP’s 
final version. 

A5.1.2. Main costs and benefits of the Governance Regulation  

Main costs  

At  all  levels  (Federal  or  regional),  interviewees  representing  agencies  and  authorities 
(AwAC,  VEKA,  CNC)  deem  difficult  to  estimate  the  costs  induced  by  the  Governance 
Regulation’s requirements, as the Government also finances a lot of projects that are not 
necessary  linked  to  the  Governance  Regulation.  Operational  teams  try  to  mutualise 
monitoring resources and methods for all energy and climate policies. 

At  federal  level,  there  is  enough  expertise  in  quantifying  GHG  emissions,  energy 
production,  consumption,  transport  and  storage,  but  not  concrete  financial  flows,  thus 
making difficult to estimate real investments. In the process of drafting the NECP update, 
this  information  was  difficult  to  obtain,  as  only  qualitative  estimates  were  available; 
interviewees (AwAC, VEKA, CNC) believe this could be a point to be improved in the next 
period. 

Although regional stakeholders have the necessary expertise to carry out activities required 
by  the  Governance  Regulation,  they  estimate  the  lack  of  staff  as  critical  bottleneck. 
However,  this  is  a  permanent  situation  that  can  sometimes  be  worsened  when  several 
reporting obligations come to term at the same time; when the workforce (or possibly the 
knowledge)  is  unavailable  internally,  a  tender  will  be  launched  to  subcontract  a 
consultancy, which is a common process that is not specific to the Governance Regulation. 
Nevertheless,  it  was  clearly  stated  by  all  interviewees  that  all  Governance  Regulation-
related activities were carried out without calling for external support. 

As  shown  in  Table  A6.1  below,  regional  stakeholders  could  more  easily  estimate  their 
overall effort related to the Governance Regulation, while Federal level stakeholders could 
only  express  the  intensity  of  the  effort.  This  can  mainly  be  explained  by  the  effort 
distribution on many different teams in different ministries and agencies, but also by the 
distribution of accountability, whereas at regional level accountability would be held by a 
reduced number of people. The distribution of tasks between working groups (WG) is also 
presented. It can be observed that while the different reporting obligations are distributed 
among various working groups in different organs, they are mostly taken care of by Experts 
and Project Managers at regional level who, according to collected testimonies, usually are 
people from the same reduced team. 

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Table 38.  Governance Regulation implementation costs 

Reporting obligation  Carried out (Y/N)  N.  and  type  of 

NECP  (art.  3,  4  Annex 
I), incl. 

Y 

MS  contribution  to  EE 
targets 

Y 

Implementation of RES 
targets 

Y 

Reporting  on  energy 
security 

Y 

Internal energy market  Y 

Reporting  on  energy 
poverty 

Y 

Reporting on R&I 

NECPR (art. 17) 

Y 

Y 

internal 
Main 
costs  (i.e.  staff 
FTEs) 

F: +++ 

R: 2-3 FTE671 

stakeholders’ 
involved  

(F): 
NEKP 

Federal 
Stuurgroep 
(=steering 
committee 
NECP) 
(joint  WG  NCC669-
CONCERE 670) 

Regional 
(R): 
Experts  &  Project 
Manager 

R:  Experts  &  Project 
Manager 

R: 0.5 FTE 

R:  Experts  &  Project 
Manager 

R: 0.5 FTE 

R:  Experts  &  Project 
Manager 

R:  Experts  &  Project 
Manager 

R:  Experts  &  Project 
Manager 

R: 0.5 FTE 

R:  Experts  &  Project 
Manager 

R: 0.2 FTE 

NCC WG PAMs 

F: +++ 

WG Projections (joint 
WG NCC-CONCERE) 

R: 2 FTE 

CONCERE 
Energy 
(EE) 

WG 
Efficiency 

CONCERE 
Renewables (REN) 

WG 

Ad-hoc WG fossil fuel 
subsidies 

NCC WG adaptation  

Energy 

669 National Climate Commission - https://www.cnc-nkc.be/fr  
670 
https://economie.fgov.be/fr/themes/energie/politique-energetique/contexte-belge/concertation-de-lenergie-
entre 
671 Regional FTE values are for one region 

Concertation 

between 

Regions 

Federal 

State 

and 

the 

the 

- 

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Reporting obligation  Carried out (Y/N)  N.  and  type  of 

Long-term 
(Art. 15) 

strategies 

Y  

Y 

Integrated 
reporting 
on  greenhouse  gas 
policies  and  measures 
and  on  projections 
(art. 18, 20-25, Annex 
I) = NECPR (art 17) 

Annual  reporting  on 
NECP (art. 26(1)) 

Y 

Climate 
National 
Adaptation 
Change 
Planning 
and 
Strategies  (NAP/NAS) 
(art. 19(1)) 

Report  on  the  use  of 
(art. 
revenues 
ETS 
19(2)) 

Y 

Support  to  developing 
countries (art. 19(3)) 

Y 

Main 
internal 
costs  (i.e.  staff 
FTEs) 

F: + 

R: 1 FTE 

F: +++ 

R: 1 FTE 

stakeholders’ 
involved  

WG  LTS  (joint  WG 
NCC-CONCERE) 

NCC  WG  PAMs  (art 
118) 

NCC  WG  Projections 
(art 18) 

CONCERE  WG  REN 
(art 20) 

CONCERE WG EE (art 
21) 

CONCERE 
security ? (art 22) 

energy 

CONCERE 
market ? (art 23) 

energy 

CONCERE 
poverty ? (art 24) 

Energy 

CONCERE RI&D ?(art 
25) 

F: Unclear 

R: 0.5 FTE 

Wallonia: 
Energie, AWAC 

SPW 

Flanders: VEKA 

Brussels:  Bruxelles 
Environnement 

NCC WG Adaptation  F: ++ 

R: 2 FTE 

NCC WG Register 

F: + 

R: 0.2 FTE 

NCC  WG  Reporting 
Climate Finance 

F: + 

R: 0.3 FTE 

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Reporting obligation  Carried out (Y/N)  N.  and  type  of 

stakeholders’ 
involved  

Main 
internal 
costs  (i.e.  staff 
FTEs) 

Annual  reporting  on 
GHG  inventories  (art. 
26 (2)) 

Y 

Final  greenhouse  gas 
inventory  report  (art. 
26(3)) [from 2023] 

Y 

CCIEP672 
Emissions 

WG 

F: + 

R: 0.5 FTE 

CCIEP WG Emissions  F: +++ 

R: 0.5 FTE 

? 

R: 0.2 FTE 

Y 

NCC WG PAMs 

+ 

NCC WG Projections 

Reporting on the 2020 
energy 
efficiency 
national targets  

Member  States  shall 
establish,  operate  and 
seek  to  continuously 
national 
improve 
inventory  systems  to 
estimate 
anthropogenic 
emissions  by  sources 
and  removals  by  sinks 
of  greenhouse  gases 
(art. 37) 

Key:   

+   little effort, can easily be integrated to workload. 

++   significant effort, difficult to integrate to workload. 

+++    important  effort,  which  can  lead  to  overtime  and  lesser  quality/granularity  to 
respect deadlines. 

Main benefits  

In  order  to  respect  its  reporting  obligations,  Belgium  had  to  better  structure  its 
interinstitutional communication, between federal and regional levels, different ministries 
and  agencies  but  also  between  “silos”  within  ministries  and  agencies,  since  energy  and 
climate  are  often  dealt  with  by  different  teams/ministries  at  a  given  level.  This  already 
resulted in a better coordination between ministries. 

Federal authorities and regional agencies particularly highlighted the importance and the 
usefulness of working groups organised by the European Commission to support them in 

672  Coordination  Committee  for  International  Environmental  Policy  -  https://www.health.belgium.be/en/cciep-
coordination-committee-international-environmental-policy 

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their reporting mission; nevertheless the lack of resources and available staff was pointed 
out as a major bottleneck to their regular participation in such encounters. 

Table 39 summarising stakeholders’ answers well reflects the analysis above. 

Table 39.  Possible benefits from the Governance Regulation 

Possible benefits 

Type 
of 
stakeholder 

Savings in time and/or 
resources  for  planning 
and reporting  

Benefit 
experienced 
and/or 
perceived  (Y/N, 
which one) 

R: Not really 

of 

Motivation/example 
benefit(s) 
information  most 
possible, 
quantitative information)  

the 
qualitative 
(if 
likely 
by 

backed-up 

– 

F:  Experience  of  collecting  data  for 
Policies and Measures (PAMs) led to 
decide to automate requests to the 
various  departments  concerned. 
Until  now,  the  exchange  of  large 
Excel files has shown its limitations, 
and  a 
them 
tool  will  replace 
(work/reflection in progress). 

R:  More  quantitative  data 
provide. 

to 

reasons 

for 
Possible 
(e.g. 
savings 
of 
rationalisation 
reporting, 
of 
templates,  use  of  IT 
tools) 

use 

Improved  quality  and 
of 
timeliness 
information produced  

WG 
Projections 

for 

Y 

F: 
projections 
(better 
alignment 
Energy/Climate 
assumptions) 

WG PAMs 

N  for  timeliness 
(NECPR template 
available 
too 
late) 

R: Not really 

R: Not really 

R: Y 

visibility 

of 
Higher 
different 
but 
interconnected  policy 
domains  

Higher  coherence  of 
planning  and  reporting 
timelines 
and 
procedures 

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Higher  coordination  of 
different 
competent 
authorities/Ministries  

Federal  Civil 
servants 
: 
Federal  Task 
Force 

F: Y 

R: Y 

Better 
established 
processes,  policies  and 
procedures  

Federal 
climate law 

F: Y 

R: Not really 

Better 
information 
about the Energy Union 
implementation 

R: Not really 

R: Already clear 

Better 
certainty 

investor 

R: Not really 

Any  other  benefit  (if 
mentioned 
by 
stakeholders) 

R: Not really 

A concrete  example of  Governance Regulation  use is a  court  case launched by a citizen 
movement  called  Affaire  Climat673  (or  KlimaatZaak)  on  climate  denouncing  the  Belgian 
State for its inaction in this matter. The verdict674 issued on November 30th 2023 imposes 
on Belgium (all levels) a higher emission reduction target; the court will use the final NECP 
to monitor and track whether the different governments have reached their revised targets. 

A5.1.3. Public consultation and multilevel climate and energy dialogues (MCEDs) 

Public consultation 

The  EU  Directive  2001/42/CE  on  the  environmental  impact  of  plans  and  programmes 
imposes that for environmental planning measures, public consultations must be held. This 
procedure  is  considered  as  “very  heavy”;  in  the  former  planning  framework  (pre- 
Governance Regulation), the whole consultation process had to be paper-based and paper 
versions of impact assessments were sent to communes for feedback. Consultations would 
take more than a year. 

In  2023  in  Wallonia,  for  the  regional  energy  and  climate  plan,  a  citizen  panel  was 
constituted, with members selected by random draw, and invited to give their opinion on 
the plan. The results should be made public early 2024. This consultation falls under Article 
10 definition. 

Multi-level climate and energy dialogues 

Regarding MECDs as defined in Art. 11 of the Governance Regulation, there is no evidence 
that  such  an  initiative  was  implemented  in  Belgium,  neither  the  draft  NECP  nor  the 
interviewees reported any known initiative. According to the collected testimonies, it can 
be  assumed  that  such  dialogues  would  possibly  overlap  with  existing  cooperation 
structures (NCC, CONCERE, CELINE) and therefore were not pursued further. This type of 
dialogue could however carry added value compared to existing structures in that they also 
welcome representatives from sectors such as industry, businesses, NGOs and civil society 
associations. 

673 See: https://affaire-climat.be/ 
674 
14c33a82d017_SP52019923113012320+fr.pdf 

See: 

https://prismic-io.s3.amazonaws.com/affaireclimat/a2250051-e0b7-4488-8944-

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Regarding the LTS, no consultation was held so far. 

A5.1.4. Regional cooperation 

As member, Belgium had exchanges with the following organisations: 

  The  PENTA  Forum675:    The  Pentalateral  Energy  Forum  is  a  regional  cooperation 
structure  between  Belgium,  the  Netherlands,  Luxembourg,  Germany,  France, 
Switzerland and Austria. Its latest joint statement676 defines the members’ vision 
for a decarbonized electricity system; 

  The  North  Seas  Energy  Cooperation677  (NSEC):  Belgium,  Denmark,  France, 
Germany,  Ireland,  Luxembourg,  the  Netherlands,  Norway,  Sweden  and  the 
European Commission. It supports and facilitates the development of the offshore 
grid development and the large renewable energy potential in the region. 

These  high-level  exchanges  about  objectives  regarding  renewables’  development  were 
compiled in a joint NECP chapter 678 that was integrated to the Belgian draft NECP in the 
Regional  Cooperation  section.  This  joint  chapter  develops  these  groups’  member  states’ 
willingness to decarbonise through electrification and wider deployment of solar and wind 
electricity production. 

A5.1.5. Compliance mechanisms  

Overlapping of reporting periods in different fields (e.g. energy and adaptation) and/or at 
different levels (regional and national but also European and international, e.g. UNFCCC) 
are perceived as a lack of coordination resulting in overloaded times. The example of NECP 
drafting and NECPR update happening on the same period was mentioned several times. 
The European Commission’s reporting timeline  should also take into consideration  other 
reporting requirements, such as UNFCCC’s, which analyses could feed each other instead 
of belonging to separate workstreams and could further generate policy coherence issues, 
as it is the case currently according to regional agencies. 

In general, the number of policies and measures to be monitored was cited as an obstacle 
slowing works down. As a result, reporting teams with limited staff must “cluster” them to 
assess them in the imparted time, thus resulting in a lower definition in the assessment.  

Regional agencies, while deploring their lack of resources to further participate in EU-led 
initiatives, clearly highlighted the crucial role of working groups organised by EU Services, 
which allow for more informal exchanges between professionals working at various levels 
of the compilation value chain. For example, in these meetings, actors from regions could 
obtain first-hand guidance from EU and/or national services, while national and EU services 
could  receive  feedback  on  how  their  initiatives  are  perceived  at  local  level,  if  they  are 
successful, what could be improved. 

Regarding  the  reporting  system,  ReportNET3  is  perceived  as  an  improvement  from  the 
previous  system,  whereas  ReportENER  is  still  considered  as  too  complicated,  asking  for 
very  specific  data  that  can  hardly  be  obtained.  Also,  reporting  can  be  complicated  for  a 
country  like  Belgium,  where  the  information  must  be  entered  in  the  system  from  three 
different regions, which can be time-consuming due to double entries and cross-checking. 

675  The  Pentalateral  Energy  Forum  is  a  regional  cooperation  structure  between  Belgium,  the  Netherlands, 
Luxembourg,  Germany,  France,  Switzerland  and  Austria  -  https://www.benelux.int/fr/info-citoyen/benelux-
plus/forum-pentalateral-de-lenergie/ 
676 
56gyeF0YvBgPyZlKDUhk.pdf?dl=Statement+van+het+Pentalaterale+Energie+Forum+over+een+CO%E2%82
%82-vrij+elektriciteitssysteem+in+2035.pdf 
677 https://energy.ec.europa.eu/topics/infrastructure/high-level-groups/north-seas-energy-cooperation_en 
678 See: https://www.benelux.int/wp-content/uploads/2023/12/Statement-by-Penta-Ministers-on-a-joint-vision-
for-a-decarbonized-electricity-system-short.pdf 

https://energeia-binary-external-prod.imgix.net/9eOe99-

See: 

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Also, users do not necessarily have a link with the IT system they use, thus leading them 
to add the values manually. 

The  major  issue  faced  by  Belgium  in  drafting  and  submitting  the  draft  NECP  to  the 
European  Commission  is  the  lack  of  proper  distribution  of  tasks  between  different 
participating authorities. The major issue faced by Belgium in drafting and submitting the 
draft NECP to the European Commission is the lack of proper distribution of tasks between 
different participating authorities. The insufficient consideration for this issue led to delayed 
submission of the draft. A burden-sharing exercise should therefore be carried out while 
designing the NECP drafting workplan. 

A5.1.6. Lessons learnt and recommendations  

Lessons learnt 

The proximity of deadlines for 2023’s NECPR and the NECP drafting put a lot of pressure 
on the teams, since they needed to  run very  similar  reporting processes twice.  This led 
respondents  to  wonder  whether  an  integration  of  NECP  drafting  and  NECPR  could  be 
possible in the case this deadline proximity occurs again. 

If the Regulation’s recast was resulting in new or revised reporting obligations, the effort 
should be quantified, in order for local teams to plan the effort and assess whether they 
should recruit new persons or ensure the reporting with existing resources. 

Adaptation  reporting  too  frequent  for  slowly  evolving  metrics  -  Adaptation  measures 
happen on the long run and these short-term reporting obligations do not streamline the 
work but instead increase the workload unnecessarily. 

At  federal  level,  there  is  enough  expertise  in  quantifying  GHG  emissions,  energy 
production,  consumption,  transport  and  storage,  but  not  concrete  financial  flows,  thus 
making difficult to estimate real investments. In the process of drafting the NECP update, 
this  information  was  difficult  to  obtain,  as  only  qualitative  estimates  were  available; 
interviewees believe this could be a point to be improved in the next period. 

Recommendations 

Along  the  interviewing  process,  the  following  recommendations  to  the  European 
Commission were made: 

  The  EC  needs  to  reconsider  the  timeline  of  the  NECPRs  and  align  them  with  the 
UNFCCC reporting requirements, as this creates a question of policy coherence.  
  The 2040 climate targets discussion needs to be taken into account in the NECPs; 
  Reporting  templates  should  be  consistently  provided  in  a  timely  manner.  For 
example,  the  digital  templates  for  NECPR’s  Policies  and  Measures  were  received 
rather late (February 2023) when reporting was due on the 15th March, immediately 
followed by the NECP reporting; 

  Requirements for NECPR Policies and Measures, wherever possible, should require 
less granularity in the policy description; since teams in charge of the reporting do 
not have the time to deep-dive in the concerned policies, they cluster them to be 
able to meet the reporting deadlines.  

Table 40.  List of stakeholders consulted 

Stakeholder type 

Position/Role 

Interview date  

National/Regional 
authority 

Team  coordinator  EU  policy  and 
industrial climate policy 

12/12/2023 

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Stakeholder type 

Position/Role 

Interview date  

National/Regional 
authority 

Head of Agency 

20/12/2023 

National/Regional 
authority 

Project 
Climate 

Manager 

Air-Energy-

22/12/2023 

3rd Party Stakeholder  Head of Group EU Affairs 

05/01/2024 

National/Regional 
authority 

Adaptation  and  Climate  Change 
Advisor 

19/01/2024 

National/Regional 
authority 

Coordinator of the National Climate 
Committee 

02/02/2024 

Table 41.  Documents reviewed  

Document type 

Author(s) and title 

Draft updated NECP 

Belgium 

Final NECP 

Belgium 

European  Commission 
Documentation 

European  Commission,  Staff  Working  Document, 
Assessment of the draft NECP 

Year 

2023 

2019 

2019 

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A5.2. Case Study – Denmark  

A5.2.1. Background  

Energy  and  climate  governance  in  Denmark  falls  within  the  competence  of  the  Danish 
Ministry  of  Climate,  Energy  and  Utilities.  Among  other  competencies,  the  Ministry  is 
responsible for national and international efforts to prevent climate change and promotes 
sustainable  policy  towards  the  green  transition.679  The  Ministry  is  also  responsible  for 
ensuring  that  the  country  is  compliant  with  the  Paris  Agreement.680  The  Ministry  works 
under  the  framework  of  the  Danish  Climate  Act,  whose  agreement  was  reached  in 
December 2019. The Climate Act sets a target to reduce Denmark’s emissions by 70% by 
2030, relative to 1990, and to achieve climate neutrality by 2050. The Act sets a rolling 
five-year target for emissions reduction. 681 

The processes are supported by different agencies, such as:682 

The Danish Energy Agency – Established in 1976, under the Ministry of Climate, Energy 
and  Utilities,  it  is  responsible  for  tasks  linked  to  energy  production,  supply  and 
consumption, as well as Danish efforts to reduce carbon emissions.683 

The Danish Council on Climate Change – Independent body of experts that advises how 
Denmark can most effectively and cost-efficiently undertake the transition to a low-carbon 
economy by 2050. 684 

The  Danish  Government  has  also  recently  set  up  a  national  energy  crisis  department 
(NEKST)  tasked  with  identifying  solutions  to  green  challenges  and  expediting  the 
implementation of the Green Political Agreements.685 

Danish NECP and LTS 

Denmark  notified  the  European  Commission  of  its  first  draft  integrated  National  Energy 
and Climate Plan (NECP) in December 2018,686 thus meeting the deadline set in Article 9 
of  the  Governance  Regulation  of  31  December  2018.  In  June  2019,  the  European 
Commission published an assessment of the draft NECPs, which was country-specific and 
contained specific recommendations for each Member State. 687 A summary of the European 

679  State  of  Green,  (2023),  About  Danish  Ministry  of  Climate,  Energy  and  Utilities,  available  at: 
https://stateofgreen.com/en/solution-providers/danish-ministry-of-energy-utilities-and-
climate/#:~:text=The%20Danish%20Ministry%20of%20Climate,efforts%20to%20prevent%20climate%20cha
nge.  
680 Danish Ministry of Climate, Energy and Utilities, (2019), Denmark’s Integrated National Energy and Climate 
Plan, available at: https://energy.ec.europa.eu/system/files/2020-01/dk_final_necp_main_en_0.pdf.  
681  Climate  change  laws  of  the  world,  Denmark  –  The  Climate  Act,  available  at:  https://climate-
laws.org/document/the-climate-act_dae7.  
682 The list is illustrative and not exhaustive. 
683  Danish  Energy  Agency,  About  the  Danish  Energy  Agency,  available  at:  https://ens.dk/en/about-us/about-
danish-energy-agency.  
684  Danish  Council  on  Climate  Change,  About  the  Danish  Council  on  Climate  Change,  available  at: 
https://klimaraadet.dk/en/about-danish-council-climate-change.  
685  Danish  Ministry  of  Climate,  Energy  and  Utilities,  (2023),  Draft  Updated  NECP,  available  at: 
https://commission.europa.eu/document/download/31895e48-37c3-46fe-8a8f-
8f61fbff6724_en?filename=EN_DENMARK%20DRAFT%20UPDATED%20NECP.pdf.  
686  Danish  Ministry  of  Climate,  Energy  and  Utilities,  (2018),  Draft  integrated  NECP,  available  at: 
https://energy.ec.europa.eu/document/download/9bef5f79-7f6e-4acb-8b9f-
39fca0880481_en?filename=denmark_draftnecp.pdf.  
687  European  Commission,  (2019),  Staff  Working  Document.  Assessment  of  the  draft  NECP.  Available  at: 
https://energy.ec.europa.eu/document/download/3b349a81-0b2c-492c-b264-e6b492cfbeda_en.  

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Commission’s  assessment  and  recommendations  was  also  provided,  in  the  form  of  a 
factsheet.688  

The  recommendations  provided  by  the  European  Commission  were  to  be  taken  into 
consideration when preparing the final NECP. This was submitted by Denmark in December 
2019 – within the deadline of 31 December 2019. The assessment of the Danish final NECP 
was published by the European Commission in October 2020.689 

The Governance Regulation required the Member States to prepare a draft updated NECP 
by 30 June 2023. Denmark respected this deadline and submitted its draft updated NECP 
on  29  June  2023.690  The  European  Commission’s  assessment  and  recommendations  on 
Denmark’s draft updated NECP were published on 18 December 2023.691  

The Governance Regulation also required Member States to submit their first national long-
term strategies (LTS) to the European Commission by 1 January 2020. Denmark submitted 
its LTS on 20 December 2019. An assessment conducted by a contractor to support DG 
CLIMA with the assessment of the LTS concludes that the Danish LTS contains clear goals 
but is insufficiently detailed and lacks some mandatory content.692 

Denmark’s objectives, targets and contributions in the draft updated NECP 

The figure below summarises the climate and energy objectives, targets and contributions 
provided in Denmark’s 2023 draft updated NECP. 

688  European  Commission,  (2019),  Denmark  –  Summary  of  the  Commission  assessment  of  the  draft  National 
Energy and Climate Plan 2021-2030, available at: https://energy.ec.europa.eu/document/download/7d52df51-
97ab-4562-97d9-692123ad0272_en.  
689 European Commission, (2020), Assessment of the final national energy and climate plan of Denmark, available 
at: https://energy.ec.europa.eu/document/download/d7ad3cd1-84c4-4616-936e-df9ed09c1a8e_en.  
690  Danish  Ministry  of  Climate,  Energy  and  Utilities,  (2023),  Draft  update  of  the  NECP,  available  at: 
https://commission.europa.eu/publications/denmark-draft-updated-necp-2021-2030_en.  
691 European Commission, (2023), Commission Recommendation, Assessment and Factsheet of the draft updated 
National 
at: 
https://commission.europa.eu/publications/commission-recommendation-assessment-swd-and-factsheet-draft-
updated-national-energy-and-climate-12_en.  
692  Ricardo  Energy  &  Environment,  Assessment  of  the  Long-Term  Strategies  of  EU  Member  States,  Denmark, 
available at: https://ec.europa.eu/clima/sites/lts/lts_dk_summary_en.pdf.  

Denmark, 

available 

Climate 

Energy 

Plan 

and 

of 

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Figure 54. Denmark’s key objectives, targets and contributions 

Source:  European  Commission  (2023)  Factsheet:  Denmark’s  Draft  Updated  National  Energy  and 
Climate Plan.693 

A5.2.2. Main costs and benefits of the Governance Regulation  

This section provides an overview of the main costs and benefits linked to compliance with 
the  obligations  of  the  Governance  Regulation.  As  it  was  only  possible  to  conduct  two 
interviews in Denmark – with Danish national authorities –, the information in this section 
is not fully comprehensive.  

Main costs  

Given the comprehensiveness of the NECP and the different aspects that it touches upon, 
numerous staff were involved in the drafting. This complicates the quantification of internal 
costs.  

One national authority explained that 20-30 people were involved in the work on the NECP. 
Of these, one person was responsible for each chapter and subchapter of the NECP, and 
other team members participated as contributors or in a quality assurance role.  

Of the 20-30 people involved in preparing the NECP, 5-10 people were responsible for the 
main chapters and comprised the  core team.  The core team was then supported by the 
remaining colleagues. The drafting of the NECP occupied around half the time of the 5-10 
core team members, while the other contributors used less time. Costs were higher during 
the first round of drafting of the NECP in 2018, because staff had to familiarise themselves 
with a new format and new type of requests.  

Fewer team members contributed to the drafting from other national authorities. 

No other major costs were reported, as the main cost was staff time.  

693  European  Commission,  (2023),  Factsheet  –  Denmark’s  Draft  Updated  National  Energy  and  Climate  Plan, 
available 
https://commission.europa.eu/document/download/ec51a283-b9e3-4ab4-aa00-
1a5dce4b4ef9_en?filename=Factsheet_Commissions_assessment_NECP_Denmark_2023.pdf.  

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One  national  authority  that  was  interviewed  shared  that  although  the  objective  of  the 
Governance  Regulation  of  streamlining  reporting  is  worthy,  the  complexity  of  certain 
reporting requirements might generate some burden. 

The  authority  also  shared  that  another  potential  source  of  burden  is  the  misalignment 
between the multiple deadlines stipulated in the Governance Regulation and those set by 
other  international  obligations,  such  as  those  set  by  the  UNFCCC  ,  as  well  as  national 
reporting  frameworks.  As  a  result,  staff  duplicate  effort  by  working  twice  on  similar 
deliverables with different deadlines and different reporting styles.  

One of the national authorities interviewed had a role in the drafting of other reports, such 
as the integrated national energy and climate progress report. Compared to the NECP, this 
smaller report required less participation from the national authority – only 5-10 people 
were  involved.  Similarly,  the  team  also  contributed  to  the  integrated  reporting  on 
greenhouse  gas  policies  and  measures  and  on  projections,  but  the  stakeholder  did  not 
elaborate on the costs involved in this.  

Concerning the Reporting on 2020 targets, according to one national authority, the time 
required  for  the  completion  of  this  Report  is  already  included  in  the  amount  of  time 
indicated for the completion of the NECP. Indeed, the stakeholder indicated that given the 
standardising and consolidated nature of the process on this report, it was not excessively 
time consuming.    

Main benefits  

Given  the  limited  stakeholder  input,  it  is  not  possible  to  draw  solid  conclusions  on  the 
benefits of the Governance Regulation.  

One  of  the  authorities  interviewed  explained  that  most  data  required  to  meet  the 
Governance Regulation’s reporting obligations were already collected as national statistics. 
Consequently, the reporting process mainly entailed adapting the report to the new model. 
Nevertheless,  the  stakeholder  emphasised  that  the  reporting  requirements  of  the 
Governance Regulation also provided an occasion to collect new and additional data, such 
as on the consumption of biomass for energy purposes.  

One  authority  indicated  that  the  guidance  and  support  received  from  the  European 
Commission during the reporting process was useful, although they also emphasised that 
it  was  sometimes  received  too  late,  given  the  deadlines  for  submission.  The  national 
authority  shared  that,  during  the  early  stages  of  the  new  process,  there  was  a  learning 
curve for all the stakeholders and that it would have been preferable to receive guidance 
and support at an earlier point in this process.  

One  national  authority  noted  that  the  Governance  Regulation  mostly  aggregated  and 
duplicated pre-existing reporting obligations, albeit with a different timing. In this respect, 
an extensive added value was not perceived.  

A5.2.3. Public consultation and multilevel climate and energy dialogues  

This section of the case study focuses on Denmark’s compliance with the obligations set in 
Article  10  (on  public  consultation)  and  Article  11  (on  multilevel  climate  and  energy 
dialogues) of the Governance Regulation.  

Public consultation 

Article  10  of  the  Governance  Regulation  requires  Member  States  to  ensure  public 
participation in the preparation of the draft NECPs and national LTSs. It sets timeframes 
for the public to be informed and to participate by expressing their views.  

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According to an assessment conducted by an external contractor for DG CLIMA, Denmark 
did not carry out a public consultation to support the drafting of its national LTS.694 This 
presents a gap in one of the mandatory elements foreseen by the Governance Regulation. 

A public consultation was, however, conducted for the first version of the NECP, between 
22 November 2019 and 2 December 2019. For this, the Ministry of Climate, Energy and 
Utilities used the EU Special Committee, a committee comprising around 100 stakeholders, 
interest  groups,  and  organisations  (e.g.  public  institutions,  NGOs,  companies).    The 
members of the committee were given the opportunity to express their views on the draft 
NECP, however, only 12 responses to the public hearing notice were received.695 The public 
was also given the opportunity to comment on the draft NECP when it was published on 
the Danish Ministry of Climate, Energy and Utilities’ website on 22 November 2019.696 The 
NECP for Denmark contains a summary of the public’s view and of how these views were 
considered  in  the  final  plan.  Local  and  regional  authorities  were  also  involved  via  the 
organisation  representing  the  municipalities,  named  “Local  Government  Denmark”,  and 
the organisation representing the different regions, called “Danish Regions”. Finally, the 
national Parliament was indirectly involved, as the content of the NECP draws on the Energy 
Agreement adopted in the Danish Parliament. 697 

To  update  the  NECP,  Denmark  followed  the  same  path,  namely  submitting  for  public 
consultation the draft updated NECP via the EU Special Committee. The draft was available 
for consultation from 16 May 2023 to 6 June 2023. The draft updated NECP submitted by 
Denmark to the European Commission collated and summarised the answers provided by 
stakeholders. 698  It  is  again  noteworthy  that  only  12  stakeholders  provided  input  in  this 
process. According to the assessment published by the European Commission, the public 
participation  procedure  in  Denmark  was  inadequate  to  guarantee  sufficient  public 
participation. Denmark’s draft updated NECP mentions that a longer period for consultation 
will be ensured for the final updated plan. This intention was confirmed by one authority 
during  an  interview.  The  authority  also  emphasised  that  the  NECP  is  compiled  with 
information  and  ambitions  set  in  several  pieces  of  legislation,  that  have  already  been 
discussed at the national level and for whom public consultation has been carried out.  

Multi-level climate and energy dialogues 

Article 11 of the Governance Regulation requires the Member States to establish a multi-
level  climate  and  energy  dialogue  (MLCED)  in  which  local  authorities,  civil  society 
organisations, businesses and other stakeholders can engage and discuss relevant points 
of the national energy and climate plans, including NECP and national LTS.  

The Commission’s assessment of the 2019 NECP states that Denmark should better exploit 
the potential of the MLCED to better engage with stakeholders on the different scenarios 
envisaged  for  its  energy  and  climate  policies.699  This  was  also  confirmed  in  2023  in  the 
context of the assessment of the draft updated NECP, where the Commission emphasised 
that there was little evidence of a proper MLCED during the process of updating the NECP 

694  Ricardo  Energy  &  Environment,  Assessment  of  the  Long-Term  Strategies  of  EU  Member  States,  Denmark, 
available at: https://ec.europa.eu/clima/sites/lts/lts_dk_summary_en.pdf.  
695 Danish Ministry of Climate, Energy and Utilities, (2019), Denmark’s Integrated National Energy and Climate 
Plan, available at:   https://energy.ec.europa.eu/system/files/2020-01/dk_final_necp_main_en_0.pdf 
696 Danish Ministry of Climate, Energy and Utilities (2019): Denmark’s Integrated National Energy and Climate 
Plan, available at:   https://energy.ec.europa.eu/system/files/2020-01/dk_final_necp_main_en_0.pdf 
697 Danish Ministry of Climate, Energy and Utilities (2019): Denmark’s Integrated National Energy and Climate 
Plan, available at:  https://energy.ec.europa.eu/system/files/2020-01/dk_final_necp_main_en_0.pdf.  
698 Danish Ministry of Climate, Energy and Utilities, (2023), Draft update of the NECP.  
699 European Commission, (2020), Assessment of the final national energy and climate plan of Denmark.  

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in  Denmark. 700  This  finding  is  supported  by  research  from  CAN  Europe  and  WWF  which 
identified that by 31 March 2023, Denmark had not yet set up a MCLED.701  

A5.2.4. Regional cooperation 

Article  12  of  the  Governance  Regulation  requires  the  Member  States  to  cooperate  with 
each other, exploiting all potential forms of regional cooperation, to meet the objectives of 
their  NECP.  The  2019  Danish  NECP  details  the  fora  where  Denmark  cooperated  for  the 
preparation of its national plan.  

The North Seas Energy Cooperation (NSEC) is a voluntary, bottom up, market-oriented, 
regional cooperation initiative, established in 2016 by countries in the North Seas region. 702 
Denmark used the NSEC for the preparation of its NECP by gathering specific support from 
the following internal Support Groups:703 

  Support group 1: Maritime Spatial Planning and environmental assessment; 
  Support group 2: Development and regulation of offshore grids and other offshore 

infrastructure; 

  Support group 3: Support framework and finance for offshore wind projects; 
  Support  group  4:  Standards,  technical  rules  and  regulations  in  the  offshore  wind 

sector. 

Moreover,  regional  cooperation  took  place  in  the  framework  of  the  Nordic  Council  of 
Ministers, the official body for inter-governmental cooperation in the Nordic Region. The 
Nordic  cooperation  promotes  the  green  transition  of  the  Nordic  region,  to  meet  the 
ambitious  Nordic  countries’  climate  targets.  Consequently,  the  already  established 
cooperation on climate and energy matters has been further intensified.704 For instance, 
an  ad  hoc  working  group  on  national  energy  and  climate  plans  has  been  established  to 
provide a forum for cooperation on the NECP.  

The regional cooperation arrangements established by Denmark were deemed as good by 
the European Commission in its assessment of the draft updated NECP. As shown in the 
table below, of the recommendations given by the European Commission in its assessment 
of  the  final  NECP,  two  were  considered  as  fully  addressed  and  one  (on  research  and 
innovation) only partially addressed.   

Table 42.  European  Commission  assessment  of  the  final  NECP  of  Denmark:  regional 

cooperation 

Recommendation 
cooperation 

on 

regional 

Status 

Commission’s assessment  

regional 
the  already  good 
Expand 
cooperation  arrangements,  in  particular 
with  the  other  Nordic  (Finland,  Iceland, 

Fully 
addresse
d 

The  contribution  to  security  of  supply 
from  biogas  has  historically  been  low. 
This is because the share of biogas in the 
natural  gas  grid  has  been  limited,  and 

700 European Commission, (2023), Commission Recommendation, Assessment and Factsheet of the draft updated 
National Energy and Climate Plan of Denmark.  
701 CAN Europe; WWF, (2023) Public participation in national energy and climate plans. Evidence of weak and 
uneven compliance in Member States  
702 Danish Ministry of Climate, Energy and Utilities, (2019), Denmark’s Integrated National Energy and Climate 
Plan. 
703 Danish Ministry of Climate, Energy and Utilities, (2019), Denmark’s Integrated National Energy and Climate 
Plan. 
704 Danish Ministry of Climate, Energy and Utilities, (2019), Denmark’s Integrated National Energy and Climate 
Plan. 

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Status 

Commission’s assessment  

Recommendation 
cooperation 
Norway and Sweden) and Baltic (Estonia, 
Latvia and Lithuania) 

regional 

on 

countries 
mechanisms. 

to 

other 

cooperation 

Possible areas for enhanced cooperation 
in  renewable  energy  include  planned 
statistical  transfers  or  hybrid  renewable 
projects,  where  offshore  wind  electricity 
is connected to more than one market. 

Fully 
addresse
d 

The 

there are ample opportunities for natural 
gas  supplies  from  the  North  Sea  and 
Germany. 
national 
transmission system operator Energinet 
into  various 
looking 
is 
operational  solutions  in  close  dialogue 
with Danish stakeholders. 

currently 

Danish 

Seas 

Denmark works together with the other 
Cooperation 
Energy 
North 
countries  on  the  possibilities  for  joint 
offshore-wind  projects  that  would  be 
connected  to  –  and  supported  by  – 
several  Member  States.  This  includes 
work  on  possible  ‘hybrid’  solutions  that 
would: (i) use cross-border solutions for 
connecting  offshore  wind  farms  to  the 
grid;  and  (ii)  seek  synergies  in  both 
interconnection 
between 
countries, and the corresponding market 
arrangements.  

capacity 

In research and innovation, these include 
alignment  of 
research  programmes 
coordinated funding, and identification of 
synergies with other Member States and 
with Union’s programmes and initiatives. 

Partially 
addresse
d 

ERA-NETS  are  mentioned,  but  more 
alignment could have been listed.  

Source:  European  Commission  (2020)  Staff  Working  Document.  Assessment  of  the  final  national 
energy and climate plan of Denmark. Annex  

In  the  European  Commission’s  recommendations  on  the  draft  updated  NECP,  issued  in 
December 2023, the European Commission invited Denmark to “Expand the already good 
regional  cooperation  by  pursuing  efforts  to  sign  all  the  needed  bilateral  solidarity 
arrangements for the security of gas supply with its neighbours (Poland), including those 
arising  from  the  building  of  new  cross-border  infrastructure”.705  The  assessment  of  the 
implementation of these new recommendations has not yet been carried out. 

705 European Commission, (2023), Commission Recommendation on the draft updated integrated national energy 
at: 
Denmark 
and 
https://commission.europa.eu/document/download/13258c5a-f447-4656-bbc9-
29a4e8adcb0e_en?filename=Recommendation_draft_updated_NECP_Denmark_2023.pdf.  

2021-2030, 

available 

covering 

climate 

period 

plan 

the 

of 

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A5.2.5. Compliance mechanisms  

This section of the case study provides an overview of the extent to which Denmark has 
progressed towards addressing the European Commission’s recommendations provided to 
the first draft NECP, and the quality of the updated NECP and LTS.  

The European Commission issued 10 recommendations on the first draft Danish NECP, 706 
which  were  divided  into  21  recommendations.  According  to  the  European  Commission’s 
assessment  of  the  final  NECP,  published  in  2020,  Denmark  addressed  only  some  of  the 
recommendations provided, with room for improvement, as shown in the figure below.  

Figure 55. Implementation of Commission’s recommendations in the Danish NECP (n=21) 

Source:  ICF  based  on  European  Commission  (2020)  Staff  Working  Document.  Assessment  of  the 
final national energy and climate plan of Denmark. Annex  

According  to  one  national  authority  that  was  interviewed  in  Denmark,  one  of  the  main 
compliance challenges for national authorities, is the very tight timeline for gathering all 
the required information.  

The European Commission’s assessment of  Denmark’s draft updated  NECP, published in 
December 2023, recognises that the draft updated NECP refers to the revised energy and 
climate  targets  agreed  under  the  Fit  for  55  Package  and  the  RePowerEU  plan,  but  it 
concludes  that  the  Danish  plan  is  not  convincing  on  how  the  climate  targets  will  be 
reached. 707 

706  European  Commission,  (2019),  Commission  Recommendation  on  the  draft  integrated  National  Energy  and 
Climate Plan of Denmark covering the period 2021-2030.  
707 European Commission, (2023), Assessment of the draft updated National Energy and Climate Plan of Denmark.  

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The  table  below  provides  a  summary  of  the  European  Commission’s  assessment  of  the 
draft updated NECP of Denmark. 

Table 43.  European Commission’s assessment of the draft updated NECP of Denmark 

Topic 

Summary of European Commission’s assessment (2023) 

GHG emissions 

The  plan  provides  emission  projections  demonstrating  that  with 
existing policies and measures Denmark is not on track to meet its 
national greenhouse gas target of -50% in 2030 compared to 2005 
levels; 

There is the need for more ambitious climate action. 

LULUCF 

The draft updated projections in the plan indicate that Denmark will 
fall short of the 2030 ambition; 

The  draft  does  not  clearly  set  out  a  pathway  to  increase  the  land 
sector’s contribution to the EU’s overall enhanced climate target; 

The  draft  does  not  provide  a  clear  implementation  timeframe  nor 
quantification of the impacts of specific policies and measures; 

The draft lacks information on the status and  progress in ensuring 
higher  tier  levels  and  geographically  explicit  datasets  needed  to 
ensure the robustness of net removal estimates. 

CCUS 

No split into ETS and non-ETS sources has been provided; 

The  information  on  the  process  for  assessing  the  volumes  of  CO2 
emissions  to  be  captured  and  the  potential  storage  capacity  is  not 
always very detailed. 

Paris Agreement  The draft does not address how and when fossil fuels subsidies will 

be phased out. 

Adaptation 
climate change 

to 

The draft updated  NECP does not contain adequate analysis of the 
relevant  climate  vulnerabilities  and  risks  to  the  achievement  of 
national objectives, targets, and contributions  and the policies and 
measures in the dimensions of the Energy Union; 

The  link  to  the  specific  Energy  Union  objectives  and  policies  is  not 
specified or quantified; 

to  support  Denmark´s 
Adaptation  policies  and  measures 
achievement of national objectives, targets and contributions under 
the Energy Union are not properly described. 

Renewable 
energy 

The  draft  updated  plan  puts  forward  a  contribution  for  a  share  of 
70.9% of the country’ gross final energy consumption by 2030, which 
is significantly above the share of 60%; 

The  draft  plan  includes  specific  trajectories  for  renewables  in  the 
electricity,  transport,  heating  and  cooling  sectors  but  does  not 
provide the trajectories for buildings and industry; 

The  plan  does  not  provide  any  details  on  renewable  fuels  of  non-
biological origin (RFNBOs). 

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Topic 

Summary of European Commission’s assessment (2023) 

Energy 
efficiency 

The  draft  updated  NECP  is  a  very  preliminary  update  of  the  2020 
plan; 

Several key elements are missing such as the 2030 energy efficiency 
targets  and  the  expected  impact  of  measures  in  terms  of  energy 
savings, accordingly a comprehensive assessment of the plan cannot 
be completed. 

Buildings  

The draft updated NECP does not update the ambition of the 2020 
long-term  renovation  strategy  (LTRS)  in  relation  to  targets  and 
indicators  such  as  building  renovation  targets,  energy  savings  and 
CO2 emission reduction. 

Energy security  The draft updated plan  convincingly sets  out measures to  enhance 

the security of gas, oil and electricity supply; 

The  draft  does  not  sufficiently  demonstrate  how  emergency 
measures  adopted  in  response  to  Russian  invasion  of  Ukraine,  in 
particular with regard to gas demand reduction, are integrated into 
the medium-term planning towards 2030. 

Oil 

The draft updated NECP contains few details on efforts undertaken 
to phase out Russian oil; 

The draft updated plan does not include a target for energy storage. 

Internal market  Denmark  is  exemplary  with  regards  to  electricity  interconnection, 
level  already  significantly 

interconnectivity 

with  the  current 
exceeding the EU target for 2030. 

Energy poverty 

The draft updated NECP indicates an engagement to launch work that 
will  tackle  energy  poverty  in  line  with  the  recent  EU  legislative 
developments in this field. 

Research, 
innovation, 
competitiveness, 
skills dimension 

This dimension in draft updated NECP is well developed; 

The draft updated plan did not provide a breakdown of research and 
innovation funding per public and private investors and does not set 
the share of green R&I compared to the overall R&I; 

The plan provides limited information on the investments needed for 
the  manufacturing  of  key  components  and  equipment  for  net-zero 
technologies; 

The  draft  updated  NECP  does  not  include  information  on  potential 
skills shortages in strategic subsectors. 

Just transition 

Only partially addressed in the draft updated NECP; 

There is little analysis of the social, employment and skills impacts, 
including distributional impacts, of the climate and energy transition; 

The plan does not detail the resources dedicated for supporting a just 
transition. 

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Topic 

Summary of European Commission’s assessment (2023) 

Alignment  with 
other  planning 
tools 

The  draft  updated  NECP  appears  consistent  with  the  recovery  and 
resilience plan (RRP); 

The measures in the draft updated plan address the 2023 European 
Semester country specific recommendations. 

Investment 
needs 

The  draft  updated  plan  does  not  include  information  on  expected 
investment needs to implement the planned policies and measures; 

For  the  analytical  base,  details  on  projections  of  the  scenario  with 
existing measures (WEM) are reported, but the impacts of additional 
measures adopted until 1 January 2024 are still missing; 

The draft updated NECP contains a macro-economic assessment, but 
it is not sufficiently developed or robust. 

Source: Summary based on European Commission Assessment of the draft updated National Energy 
and Climate Plan of Denmark, 2023. 

The  contractor  responsible  for  assessing  the  national  LTS  concluded  that  although 
Denmark’s national LTS defines a clear goal for Denmark to reach net-zero emissions by 
2050, it does not clearly specify if the target includes emissions from international aviation 
and maritime. 708  

The analysis maintains that the LTS is insufficiently detailed and omits several mandatory 
elements, namely: 

  Public consultation; 
  Energy sector’s emission reductions; 
  Emissions reductions in buildings; 
  Estimated investment needs; 
  Socio-economic impact assessment.709 

Finally, the analysis emphasises that the LTS includes some of non-mandatory contents, 
but with projections limited to 2040.710 

According  to  a  study  recently  conducted,  the  Governance  Regulation’s  objective  to 
establish  an  integrated  framework  for  planning  and  reporting  of  national  energy  and 
climate policies has not yet been achieved. 711 

The  study,  which  contained  an  analysis  of  the  implementation  of  the  Governance 
Regulation  in  several  Member  States,  including  Denmark,  showed  that  the  main  critical 
elements  pertained  to  different  layers.  These  included  the  national  administrative 
structures, the national implementation of the Governance Regulation and finally, some of 
them were more connected to the Regulation  design itself. The table  below provides an 
overview of the main issues and recommendations identified in the study. While not all the 

708 Ricardo Energy & Environment, Assessment of the Long-Term Strategies of EU Member States, Denmark. 
709 Ricardo Energy & Environment, Assessment of the Long-Term Strategies of EU Member States, Denmark. 
710 Ricardo Energy & Environment, Assessment of the Long-Term Strategies of EU Member States, Denmark. 
711 Wachsmuth, Jakob et al. (2023): National Energy and Climate Plans: Evidence of Policy Impacts and Options 
for more Transparency. A Meta Study assessing Evaluations of selected Policies reported in the Danish, French, 
German, Slovenian, and Swedish Plan. Final report. Dessau-Roßlau: German Environment Agency, available at: 
https://www.ecologic.eu/19479.  

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issues identified as critical in the case of Denmark, they need to be considered in the future 
reporting cycles.   

Table 44.  Main  issues  and  recommendations  identified  in  the  Wachsmuth,  Jakob  et  al. 

(2023) study 

Issues 

Recommendations 

Knowledge  gaps  with 
regard to PaM impacts 

Undertaking of ex-post evaluations of the main PaMs, on 
a regular basis; 

Insufficient  transparency 
about  the  selection  of 
policies  and  the  impacts 
on NECPs 

Gaps in reporting of PaMs 
in  relation  to 
impacts 
climate 
energy 
objectives 

and 

the 

Insufficient  transparency 
and 
in 
development 
of 
evaluations 

use 

GHG impacts included in the agricultural evaluations; 

Creation  of  a  centralised  platform 
transparency. 

for 

increasing 

The NECP would benefit from more detailed description of 
the  role  of  existing  and  planned  PaMs,  including  the 
explanation of which PaMs are key and why; 

Ex-ante  estimates  on  the  emission  reduction  for  the  key 
PaMs, which take into account the findings of the ex-post 
evaluations. 

Enforce a higher degree of harmonisation between NECPs, 
Progress Reports and PaM reports; 

Harmonise  the  baselines  between  NECPs,  Progress 
Reports and PaM reports building on the requirements of 
the NECPs, i.e. allowing for a comparison between current 
and planned policies; 

if a Member State keeps the PaM report separate from the 
NECP progress report, the progress  report should clearly 
reference the PaM report and corresponding evaluations of 
PaMs; 

Make reporting the contributions of PaMs to RES expansion 
mandatory if available.  

Harmonisation  of  the  reporting  requirements  under  the 
EED and the Governance Regulation; 

Evaluations should be carried out on the basis of existing 
guidelines; 

Integrate requirement to measure PaM contributions into 
all evaluations; 

Improve  planning  by  using  the  same  templates  for  all 
evaluations of PaMs. 

Source: ICF based on Wachsmuth, Jakob et al. 2023: National Energy and Climate Plans: Evidence 
of Policy Impacts and Options for more Transparency. A Meta Study assessing Evaluations of selected 
Policies reported in the Danish, French, German, Slovenian, and Swedish Plan. Final report. 

A5.2.6. Lessons learnt and recommendations  

The following conclusive section of the case study details the main lessons learnt and draws 
some  recommendations,  based  on  the  evidence  collected  from  desk  research  and  the 

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limited stakeholder  consultation on the implementation of the Governance Regulation in 
Denmark.  

Evidence  collected appears to suggest that in Denmark energy and climate policy is not 
driven by the NECP, on the contrary the NECP seems more a collection of the results of 
existing policies and measures that have been deliberated separately. This emerges clearly, 
for instance, in the context of the public consultation, which albeit limited for the purpose 
of the NECP, had already been carried out separately for the single policies and measures 
that eventually flowed into the NECP. 

Overall, Denmark respected the deadlines for reporting submissions,712 which however are 
misaligned  with  the  deadlines  of  similar  reports  at  different  governance  levels  –  e.g., 
national  and  international  –  therefore  potentially  generating  burden  and  duplication  of 
efforts. This issue emerges mostly in relation to the need to adapt to different reporting 
styles, since the typology of data that has to be reported is often the same in the different 
reports. Therefore, either flexibility on the reporting style of the NECP or providing more 
guidance within a reasonable time compared to the deadline, can be recommendable. 

Moreover, according to  the desk  research conducted for the  case  study,  only 5% of the 
recommendations provided by the European Commission to the first draft NECP, had been 
fully addressed by the time of the 2020 assessment of the final NECP. Although Denmark 
worked  on  improving  the  implementation  of  the  recommendations,  it  emerges  from  the 
assessment  of  the  draft  updated  NECP  that  omissions  of  necessary  data  and  of  clearer 
information still takes place. Similarly, it emerges from desk research that the Danish LTS 
defines  the  clear  goal  of  reaching  net-zero  emissions  by  2050,  but  it  is  insufficiently 
detailed  and  omits  several  mandatory  elements.  Also  in  these  cases,  according  to  one 
authority one of the main compliance challenges was the timeline, deemed as very tight. 

Given  the  reiterative  nature  of  the  exercise,  economies  of  scale  can  potentially  be 
expected,  with  a  progressive  flattening  of  the  learning  curve  regarding  data  and 
information  to  be  collected  and  reported.  This  should,  at  least  in  theory,  contribute  to 
reduce these compliance issues.  

Table 45.  List of stakeholders consulted 

Stakeholder type 

Position/Rôle 

Interview date  

National authority 

Policy Officers  

National authority 

Policy Officers 

04-12-2023 

29-02-2024 

Table 46.  Documents reviewed  

Document type 

Author(s) and title 

NECP 

Danish Ministry of Climate, Energy and Utilities, Draft 
integrated NECP 

Year 

2018 

712 This information refers to NECP and national LTS.  

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Document type 

Author(s) and title 

Danish  Ministry  of  Climate,  Energy  and  Utilities, 
Denmark’s  Integrated  National  Energy  and  Climate 
Plan 

Danish Ministry of Climate, Energy and Utilities, Draft 
Updated NECP 

2023 

Year 

2019 

NECP 

NECP 

European  Commission 
Documentation 

European  Commission,  Staff  Working  Document, 
Assessment of the draft NECP 

2019 

European  Commission 
Documentation 

European  Commission,  Denmark  –  Summary  of  the 
Commission assessment of the draft National Energy 
and Climate Plan 2021-2030 

2019 

European  Commission 
Documentation 

European Commission, Commission Recommendation 
on  the  draft  integrated  National  Energy  and  Climate 
Plan of Denmark covering the period 2021-2030 

2019 

European  Commission 
Documentation 

European  Commission,  Assessment  of  the  final 
national energy and climate plan of Denmark 

2020 

European  Commission 
Documentation  

Commission, 

Commission 
European 
Recommendation,  Assessment  and  Factsheet  of  the 
draft  updated  National  Energy  and  Climate  Plan  of 
Denmark 

2023 

NLTs assessment 

Ricardo  Energy  &  Environment.  Assessment  of  the 
Long-Term  Strategy  of  Germany.  Summary  of  main 
findings. 

ND 

Study 

Report  

Webpage 

Webpage 

Webpage 

Webpage 

Wachsmuth, Jakob et al. National Energy and Climate 
Plans:  Evidence  of  Policy  Impacts  and  Options  for 
more  Transparency.  A  Meta  Study  assessing 
Evaluations  of  selected  Policies  reported  in  the 
Danish,  French,  German,  Slovenian,  and  Swedish 
Plan. 
report.  Dessau-Roßlau:  German 
Final 
Environment Agency. 

2023 

CAN  Europe;  WWF.  Public  participation  in  national 
energy  and  climate  plans.  Evidence  of  weak  and 
uneven compliance in Member States  

2023 

State  of  Green,  About  Danish  Ministry  of  Climate, 
Energy and Utilities 

2023 

Climate  change  laws  of  the  world,  Denmark  –  The 
Climate Act 

ND 

Danish  Energy  Agency,  About  the  Danish  Energy 
Agency 

ND 

Danish Council on Climate Change, About the Danish 
Council on Climate Change 

ND 

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A5.3. Case Study – France  

A5.3.1. Background  

Institutional background and organisation 

The preparation of the NECP and other reporting, including the NECPRs, is managed directly 
by the ministry in charge of energy and climate (namely the DGEC – General Directorate 
for Energy and Climate), including two directorates (Directorate for Energy, and Directorate 
for  Climate,  Energy  Efficiency  and  Air).  This  implies  coordination  between  the  two 
directorates.  

The  process  is  fully  led  and  implemented  by  DGEC  (no  use  of  external  contractor).  The 
reporting  obligations  are  distributed  within  the  teams  of  the  two  directorates  of  DGEC, 
according to their missions. However, other ministries or administrations (e.g. Directorate 
of  State’s  real  estate;  Directorate  in  charge  buildings’  policies;  ministry  in  charge  of 
transport; ministry in charge of agriculture) may be involved, especially to provide data.  

Moreover, a general secretariat for ecological planning (SGPE), placed under the authority 
of  the  Prime  Minister,  was  created  in  2022.  It  is  responsible  for  coordinating  the 
development  of  national  strategies  on  climate,  energy,  biodiversity  and  the  circular 
economy.  It  thus  plays  a  role  in  coordinating  interministerial  discussions  during  the 
preparation  of  the  NECP.  However,  the  SGPE  was  not  created  due  to  the  Governance 
Regulation. It is a political decision related to the national context (following the President’s 
election in April 2022). 713 

Compliance with the Governance Regulation 

Overall, France has complied with all reporting obligations of the Governance Regulation, 
though sometimes with a short delay (cf. final NECP and draft NECP update): 

  France reported its draft NECP in January 2019, final NECP in March 2020 (3-month 

delay) and draft NECP update in October 2023 (4-month delay). 

  France’s LTS is its National Low Carbon Strategy (SNBC) established by the 2015 
French law on energy transition and green growth. The version submitted as LTS is 
the one of March 2020. 

  France  published  its  first  national  adaptation  strategy  in  2007,  and  its  second 
national adaptation plan in October 2018. EEA’s Climate Adapt platform 714 mentions 
that France reported its national adaptation policy in 2023, as well as its adaptation 
portal. 

  France submitted its reporting about the achievement on the 2020 targets on time 

(early May 2022). 

  Based  on the ReportNET portal715, France is up-to-date with the annual  reporting 
obligations and the NECPR2023, with no or minor delays (less than a month) for the 

713  See  e.g.  Jacque,  M.  (2022)  Planification  écologique :  une  cellule  de  pilotage  au  cœur  de  Matignon.  Online 
article of Les Echos, June 2022. 
714 Climate Adapt :  https://climate-adapt.eea.europa.eu/en/countries-regions/countries/  
715 ReportNET :  https://reportnet.europa.eu/public/country/FR  

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annual reporting, and longer delays for parts  of the  NECP2023 (e.g.  the dataflow 
about energy efficiency reporting was reported with a 3-month delay) 

Quality of the reporting 

France’s  NECP  is  based  on  French  main  planning  documents:  the  planning  process  for 
medium  (PPE  –  multiannual  energy  planning)716  and  long  term  (SNBC  –  national  low-
carbon strategy)717. France has recently established a detailed dashboard to monitor the 
progress  and  achievements  against  the  planning  and  targets  set  in  PPE  and  SNBC.  This 
enables France to provide detailed reporting. 

The  European  Commission’s  factsheet  about  France  provides  an  overview  of  the  key 
climate  and  energy  objectives,  targets  and  contributions,  as  outlined  in  the  2023  draft 
updated NECP of France (submitted in November 2023).  

Figure 56. France’s key objectives, targets and contributions 

Source: European Commission (2023) Factsheet: France’s draft updated National Energy 
and Climate Plan 718 

France’s draft NECP update partially takes into account the new framework from the Fit-
for-55  package,  with  some  ambition  gaps,  especially  about  RES.  The  European 
Commission’s  assessment  also  highlights  that  France  fell  short  of  meeting  its  2020 
renewable energy sources (RES) target and the NECP does not indicate how it intends to 
meet its binding baseline. France did not submit a 2030 contribution in this field. 

Similarly, regarding effort sharing, the emissions projections, encompassing both existing 
and  additional  policies  and  measures,  indicate  that  France  is  not  on  track  to  meet  its 
national GHG emissions target of -47.5% by 2030, compared to 2005 levels, a gap of 1.1 
percentage points. 

On  energy  efficiency,  the  draft  NECP  update  includes  a  set  of  comprehensive  measures 
addressing most of the relevant sectors, including building, transport and business sectors. 

716 https://www.ecologie.gouv.fr/politiques-publiques/programmations-pluriannuelles-lenergie-ppe 
717 https://www.ecologie.gouv.fr/strategie-nationale-bas-carbone-snbc  
718 Factsheet_Commissions_assessment_NECP_France_2023.pdf (europa.eu)  

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However, France reports its white certificates scheme as the sole measure to Article 8 of 
the Energy Efficiency Directive (EED), thus omitting estimates of expected energy savings 
for other measures. 

The sections on energy poverty in the NECP or NECP update include detailed data for the 
assessment  on  energy  poverty  and  related  measures  in  place,  thanks  to  the  national 
energy poverty observatory (established in 2011). 

The  European  Commission’s  assessment  highlighted  information  that  was  incomplete  or 
requiring further explanation, including among others: 

 
 
 

incomplete information on the policies and measures; 

the need to improve and expand the analysis of investment needs; 

the need to explain how the policy framework identified in the NECP will contribute 
to the preparation of France’s Social Climate Plan and how the consistency between 
the two plans will be ensured. 

A5.3.2. Main costs and benefits of the Governance Regulation  

Main costs  

Overall,  the  Governance  Regulation’s  reporting  process  require  a  lot  of  coordination 
between services. The person in charge of each reporting obligation must exchange with 
various services to anticipate, gather, consolidate, and validate the information needed for 
reporting. 

No particular investment was made in new tools or IT to support the Governance Regulation 
reporting in France. Rather, DGEC has continued using the tools set up for designing and 
monitoring  the  French  low  carbon  national  strategy  (SNBC)  and  the  French  multiannual 
energy plan (PPE). Likewise, France did not make use of sub-contractors in the preparation 
of its reporting (NECPR or draft NECP update). 

The  interviewed  policy  officers  in  charge  of  the  reporting  obligations  found  it  difficult  to 
make a specific quantitative assessment of the costs that the reporting obligations of the 
Governance Regulation generate for the French ministry. They did, however, mention that 
it has generated a significant workload, particularly in 2023, as the first NECPR occurred 
at the same time as the draft NECP update had to be prepared, and the same persons are 
involved  in  both  processes.  Moreover,  at  the  same  time,  there  was  also  the  legislative 
process of the fit-for-55 package, creating an additional workload and uncertainties in what 
had to be considered in the preparation of the draft NECP update. 

Overall,  about  20  to  30  ministry  personnel  were  involved  in  the  reporting  obligations  in 
2023 (NECPR and NECP). However, this does not correspond to FTEs:  each person who 
took part in the process did their part among other tasks and activities.  

It  was  difficult  for  the  interviewed  policy  officers  to  assess  whether  the  efficiency  of 
reporting or administrative burden, had increased because of the Governance Regulation, 
especially because of the turnover in the services. None of the interviewees oversaw the 
reporting  before  the  Governance  Regulation,  nor  at  the  time  of  the  first  NECP  in  2019. 
They  acknowledged  that  the  Governance  Regulation  gathers  all  obligations  related  to 
energy  and  climate  in  a  joint  process  and  document,  but  they  also  explained  that  each 
reporting obligation remains the same and is now part of a ‘big machine’. 

The  interviewed  policy  officers  were  unsure  whether  this  enables  the  rationalisation  or 
streamlining of reporting work or saves time. Nevertheless, they mentioned that a lot of 
information is requested, in a very detailed manner. Taking the example of the Policies and 
Measures (PaMs), France  reported about 200 PaMs in its NECPR.  This  entails  entering  a 
significant amount of data and prompts the question of whether to focus on documenting 
the main measures to optimize efforts.  

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Regarding the  relevance and usefulness  of the templates and other support provided to 
the  Member  States,  the  interviewed  policy  officers  acknowledged  that  the  European 
Commission made  significant efforts in the preparatory phase. They  mentioned that the 
webinars and video recordings of tutorials were very useful. However, they also suggested 
that it could have been even better if the ReportNET platform had been fully operational 
at the time of the online sessions. This meant it was not possible to immediately test the 
information presented in the webinars, as there was some delay in the full availability of 
the platform. There were also some technical bugs in the platform which probably arose 
because this was the first NECPR and thus the first full-scale test of the online platform. 

The guidelines providing complementary detailed guidance and explanations on the data 
to  be  reported  (for  the  NECPR)  provide  a  useful  support  and  are  appreciated  by  the 
interviewed  policy  officers.  However,  because  these  guidelines  cover  all  data  fields,  the 
document is very long and requires time to be digested. 

Another important point raised by the interviewed policy officers is that it is unclear what 
is  expected  from  the  reporting  on  PaMs;  whether  the  aim  is  to  be  exhaustive  (but  less 
detailed), or instead to focus on main measures that would be documented more in detail.  

The national authorities that were interviewed reflected on their experiences of using the 
ENER  and  ReportNET  platforms.  They  explained  that  the  ergonomics  of  both  platforms 
(ENER and ReportNET) could be improved, noting that: 

  Importing and exporting data to the online platforms was challenging: 

-  Regarding  data  imports:  this  creates  extra  work  associated  with  preparing  or 

entering the data. 

-  Regarding  data  exports:  it  is  difficult  to  review  the  reported  data  or  to  share 
them with other services. This made the communication with the other services 
(within  DGEC  or  of  other  ministries)  more  difficult.  The  data  exported  from 
ReportNET could not be easily read and understood directly. Thus, the ministry 
developed an Excel  file  internally gathering all  the data in a more transparent 
way. This data file could then be shared with the other services involved. 
  Reviewing  data  in  the  platforms  was  sometimes  difficult  and  this  hindered 
proofreading  the  data  before  it  was  submitted.  A  lot  of  information  and  text  is 
required.  It  was  difficult  to  review  this  directly  in  the  tool,  and  this  made  the 
submission  process  more  time-consuming.  The  platforms  also  fail  to  provide  a 
impedes  the 
general  overview  of  data  that  have  been  entered,  which 
implementation of optimal internal data quality checks. 

During the consultation, third-sector organisations explained that the reporting processes 
of the Governance Regulation, and particularly the five-yearly cycle for the NECPs, have 
improved  the  transparency  and  availability  of  data,  especially  about  intentions  and 
objectives. When stakeholders look for recent data about progress and achievements, they 
use national sources. For example, in France, they use the reports of the High Council on 
Climate or the new dashboard of the energy transition developed by the SGPE (General 
Secretariat for Ecological Planning). Data on progress and achievements are supposed to 
be  publicly  available  from  ReportNET.  However,  the  stakeholders  did  not  find  the 
ReportNET platform user-friendly (when they knew about it). Beyond this usability issue, 
they mentioned that the ReportNET platform follows too closely a mere accounting or box-
ticking process. Consequently, the assessments from the European Commission are mostly 
limited to comparing reported implementation and achievements against plans and targets, 
only pointing out when Member States are late or off-track. Third-sector organisations thus 
stressed the importance of having national evaluation bodies. National evaluations delve 
into more detail, using more specific indicators and providing more qualitative analyses. 
When  asked  about  additional  problems  or  issues,  the  national  authorities  that  were 
interviewed mentioned that it has sometimes been difficult to understand communications 

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with  the  European  Commission  for  the  complementary  questions  related  to  the  NECPR. 
This  has  resulted  in  many  email  exchanges.  They  mentioned,  for  example,  that  some 
annexes  were  closed,  and  then  re-opened.  The  status  of  the  information  (‘submitted’, 
‘validated’, etc.) was not always clear. It was also sometimes unclear what the European 
Commission  had  taken  into  account.  Some  files  could  not  be  uploaded  to  the  online 
platform, and therefore had to be submitted by email, and were not considered as official 
communications. 

Stakeholders also noted that it is unclear what has become of the information they have 
submitted, and what it has been used for. They questioned what the return on investment 
will  be  for  the  Member  States.  Their  experience  with  the  NECPR  in  2023  is  that  the 
European Commission’s feedback is mainly limited to listing what has been reported, with 
little analysis. 

Main benefits  

One benefit highlighted by most interviewees is that the NECP process pushes to produce 
a report that covers and gathers all fields relevant to energy and climate. The interviewed 
national  authorities  found  that  it  can  be  useful  for  internal  communication  between  the 
services of the ministry and helps to avoid a siloed vision. Nevertheless, there remains a 
need for synthesis per policy area. 

In France, cross-cutting exchanges and coordination between ministries (or among units 
of the same ministry) were already in place before the Governance Regulation, due to the 
2015 French law on energy transition and green growth, which established the planning 
process for the medium (PPE) and long term (SNBC, that corresponds to France’s national 
LTS). Therefore, the Governance Regulation did not generate major changes for France in 
this field. France’s NECP is mostly a synthesis of the two main French planning documents, 
SNBC and PPE. 

Similarly, most of the data required to meet the reporting obligations of the Governance 
Regulation  are  monitored  for  national  purposes  anyway.  For  example,  the  planning 
processes  initiative  of  the  2015  French  law  induced  progressive  improvements  in 
monitoring and data availability, including the recent development at the national level by 
the  SGPE  (General  Secretariat  for  Ecological  Planning)  of  a  dashboard  to  monitor  the 
progress with ecological planning, including more than 160 indicators published in a timely 
manner.  

It is difficult to distinguish between evolutions in monitoring practices stemming from the 
national framework and those attributed to the Governance Regulation. This is particularly 
true given that France already had established processes for medium-term and long-term 
planning for energy and climate before the Governance Regulation. 

Third-sector organisations stressed that the Governance Regulation helps, as it acts as a 
spur to prepare and publish the planning documents. This is especially true of the deadlines 
introduced by the Governance Regulation. In the absence of European deadlines, national 
governments may choose to postpone the most difficult decisions or may not publish all 
the  details  that  are  reported  to  meet  European  obligations.  Most  interviewees 
acknowledged  that  one  added  value  of  the  Governance  Regulation  is  that  it  ensures 
information  is  made  available  in  a  consistent  way  and  at  the  same  time  for  all  Member 
States  which,  in  turn,  may  facilitate  benchmarking  and  comparisons.  According  to  one 
third-sector  organisation, 
increasing 
transparency and data availability, thanks to the NECPs. 

the  Governance  Regulation  contributed 

to 

However,  all  interviewees  mentioned  that  the  NECP  and  NECPR  are  unknown  by  most 
national stakeholders (and even less by the general public), and that consequently these 
documents  are  rarely  used  as  a  source  of  information  by  national  stakeholders. 
Interviewees (NCA and third-sector organisations) indicated that investors are more likely 
to know about and use the French planning documents (PPE and SNBC).  

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According  to  third-sector  organisations,  the  European  obligations  (including  those 
stemming  from  the  Governance  Regulation)  may  have  been  one  factor  instigating  the 
establishment  of  national  independent  bodies  publishing  evaluations  about  energy  and 
climate policies, like the High Council on Climate in France. The stakeholders were unsure 
if  this  has  been  the  case  in  other  countries  as  well  and  whether  other  international 
obligations, such as the Paris Agreement, also acted as a prompt.  

When  asked  specifically  about  the  experience  gained  with  the  submission  of  the  first 
NECPR, the interviewed national authorities noted that the learning curve is uncertain, as 
NECPR  cycle  is  biennial.  They  were  unsure  if  the  memory  of  the  previous  round  will  be 
retained, particularly because there may be some staff turnover in the services.  

A5.3.3. Public consultation and multilevel climate and energy dialogues (MCEDs) 

Public consultation 

The information collected in the detailed consultations conducted for the SNBC and PPE are 
summarized in the NECP. The update of the SNBC and PPE is independent from the NECP, 
and  more  generally  from  the  Governance  Regulation  process.  The  first  SNBC  was 
established by the national law on energy transition in 2015, with the objective of reducing 
France’s GHG emissions by a factor of four (i.e. -75%) relative to 1990 levels. The SNBC 
was  revised  in  2018-2019  with  the  new  target  of  carbon  neutrality  by  2050.  A  public 
consultation  about  this  revision  was  organized  early  2020.  The  new  version  (SNBC2), 
published  in  March  2020,  forms  France’s  national  LTS  reported  to  the  European 
Commission in 2020. 

Similarly, the first PPE was adopted in 2016, covering the period 2016-2023. A first revision 
process started mid-2017, including a public debate in spring 2018. A draft revision was 
published in January 2019, and was followed by a public consultation. The final revision 
(PPE2), for the period 2019-2028, was adopted in April 2020. 

The current process for updating the SNBC and PPE follows the adoption of the Energy and 
Climate Law of November 2019, that introduced the process for a new Energy and Climate 
Programming Law (LPEC). The LPEC should set the overall framework for the SNBC, PPE 
and National Adaptation Plan (PNACC), that altogether form France’s strategy for energy 
and climate (SFEC). 

The  preparation  of  the  LPEC  and  the  updates  to  the  SNBC,  PPE,  and  PNACC  involve  a 
steering committee and sectoral working groups that encompass all relevant stakeholders. 
This is complemented by several steps of public consultation: 

  First  public  consultation  (both  online,  and  with  public  meetings)  from  November 

2021 to February 2022 on the outlines and general objectives.719 

  A second public consultation (both online, and with public meetings) from October 

2022 to January 2023 about the future of France’ energy mix.720 

  Consultations  related  to  the  update  of  the  SNBC  and  PPE  have  been  planned  in 
2023-2024 (for example, the public consultation on the energy and climate strategy 
which ran from the 22 November to 22 December 2023 721). 

Working groups about the  overall  strategy (SFEC) were also  established in 2023.  These 
included members of the parliament and elected representatives from local authorities. 

719 Link to the public consultation webpage : https://www.ecologie.gouv.fr/strategie-francaise-lenergie-et-climat-
lancement-consultation-publique  
720 
climat.gouv.fr/sites/default/files/2023-03/230313_Synth%C3%A8se_concertation%20energie.pdf  
721 Link to the public consultation webpage : https://www.ecologie.gouv.fr/consultation-publique-sur-strategie-
francaise-energie-climat  

https://concertation-strategie-energie-

concertation 

webpage 

public 

Link 

the 

to 

: 

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Stakeholders and experts are also involved in the consultation process in expert working 
groups. The process for updating the PPE has, for example, included 37 working groups, 
with two meetings each on average. 

Overall, the process includes many consultation phases, that enable topics to be refined. 
This helps define the measures that will be included in the SNBC and PPE, and thereby in 
the NECP. 

The  consultation  on  the  energy  mix  aimed  to  mitigate  controversies.  It  revealed,  for 
example,  that  there  was  no  consensus  on  prioritizing  a  specific  type  of  energy  carrier; 
rather, all decarbonized energies were recognized to have a role to play. 

There will also be a public consultation for the NECP update, as required by the Governance 
Regulation. A think tank specialised in participatory approaches highlighted that organising 
sufficient  iterations  is  necessary  to  ensure  the  consultation  process  is  effective.  This 
interviewee noted that the implementation of the Governance Regulation may have created 
additional  opportunities  for  third-sector  organisations  to  contribute  to  the  debates  on 
energy  and  climate,  or  to  make  suggestions  about  how  to  involve  stakeholders  in  the 
planning processes. The consultation process and its preparation also provide opportunities 
to disseminate results from studies and recommendations. 

Nevertheless, a consultation process based on iterations may not be satisfactory. Even if 
there are more iterations now in France in the preparation of the major plans (SNBC and 
PPE), all third-sector organisations stressed that it remains unclear how the contributions 
and  comments  from  stakeholders  are  reflected  in  the  next  iteration.  Some  third-sector 
organisations shared their ‘consultation fatigue’ with some having the impression that most 
of the energy and time they have contributed to these consultations was wasted as they 
cannot see how their contribution has been used.  

Some  interviewees  representing  third-sector  organisations  had  the  impression  that  the 
main decisions had already been taken prior to the consultation and suggested that it would 
be  better  to  use  a  real  co-construction  approach,  especially  for  the  most  difficult  or 
sensitive issues.  

The  interviewees  from  third-sector  organisations  acknowledged  that  it  is  difficult  for  a 
European  regulation  to  trigger  changes  in  national  institutional  practices  that  are  often 
rooted in national institutional cultures and habits. They indicated that it is uncertain that 
European  guidelines,  like  the  ones  published  by  the  European  Commission  in  December 
2022 for the update of the NECP, would be a solution, suggesting that this would need to 
be further investigated. They identified a risk that guidelines would make Member States 
report  information  that  is  recommended  (e.g.  more  scenarios  to  compare),  without 
changing 
third-sector 
organisations  thus  suggested  a  more  pragmatic  solution  that  would  favour  experience 
sharing. 

their  decision-making  processes.  The 

interviewees 

from 

Previous research by think tanks has shown that the practices to prepare NECP and LTS 
may vary from country to country. In some countries, they are mainly prepared by one 
ministry, with limited consultation of other ministries and stakeholders. The process has 
evolved  considerably  in  France,  with  a  stronger  consultation  process  and  more 
opportunities for stakeholders to contribute to the discussions. 

Multi-level climate and energy dialogue 

- 
-  The  French  Energy  Code  requires  that  the  objectives  of  the  multi-energy 

planning (PPE) be transcribed region per region. 

According  to  the  interviewees  representing  third-sector  organisations,  the  multi-level 
dialogue process in France is clear but problematic. In practice, local authorities have had 
limited involvement in national energy planning and were not adequately considered. There 

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are few representatives from local authorities in the Steering Committee, and thereby in 
the working groups where the most important discussions happen. 

The  interviewees  of  third-sector  organisations  also  indicated  that  there  is  no  clear  link 
between the process for the national planning (SNBC and PPE) and the regional planning 
(SRADDET  –  Regional  plan  for  sustainable  development  and  territorial  equality).  This 
applies to the two ways:  

 

the  process  for  the  national  planning  does  not  really  consider  contributions  from 
regional and local levels; 

  and once the national planning is decided, there is not enough territorialization. 

A  new  process  has  been  initiated  at  the  end  of  2023  for  a  regional  planning  of  the 
transition:  the  “regional  COPs”,  co-chaired  by  the  State  representative  in  the  region 
(Prefect)  and  the  President  of  the  Regional  Council.  The  regional  COPs  include  a 
consultation  process  to  define  how  the  national  objective  should  be  transcribed  in  the 
region,  in  terms  of  distribution  per  sector  and  area.  They  should  also  define  regional 
roadmaps. It has been initiated too recently for any feedback to be available yet. 

A5.3.4. Regional cooperation 

France  already  participated  in  regional  cooperations  before  the  Governance  Regulation, 
namely the Pentalateral Energy Forum (PENTA) initiated in 2005, and North Seas Energy 
Cooperation  (NSEC)  established  in  2016  after  discussing  the  proposal  of  a  North  Sea 
Offshore Grid from 2008. France is also part of the Interconnections for South-West Europe 
high-level group set up by the European Commission. 

The  interviewed  national  authorities  indicated  that  no  further  regional  cooperation  is 
currently being considered. Interviewees from third-sector organisations confirmed that, 
in  terms  of  regional  cooperation,  there  have  been  few  developments  compared  to  the 
situation before the Governance Regulation. 

The existing regional cooperations have provided a platform to exchange and elaborate a 
common vision. For example, the cooperation in the PENTA forum led to preparing joint 
chapters  including  in  the  NECPs  of  the  member  countries  of  the  PENTA  forum.  The 
alignment of the timeline among policy areas  due to the Governance  Regulation did not 
really influence the regional cooperations.  The  national authorities interviewed indicated 
that these exchanges happen anyway. Overall, the Governance Regulation has thus had 
little effect on these regional cooperations. 

Table 47.  European  Commission  assessment  of  the  final  NECP  of  France:  regional 

cooperation  

Recommendation 
cooperation 

on 

regional 

Status 

Commission’s assessment  

Largely 
addresse
d 

Intensify  the  existing  good  regional 
cooperation with Spain, Portugal and the 
Pentalateral  countries.  The  focus  of  the 
regional exchanges should be on internal 
energy  market  and  energy  security 
areas.  Continue  the  cooperation  with 
Portugal  and  Spain,  in  particular  on 
cross-border  and  cross  regional  energy 
interconnections. Consider strengthening 
measures related to regional cooperation 
the  area  of  renewable  energy. 
in 

largely 

addressed 

the 
France 
recommendation  to  strengthen  regional 
cooperation. 
regional 
cooperation 
is  highlighted  with  the 
Energy  Pentalateral  Forum  and  the 
North 
Cooperation 
Energy 
initiatives.  

In  particular, 

Seas 

France  has  tried  to  improve  regional 
cooperation in view of improving energy 
security. 

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Recommendation 
cooperation 

on 

regional 

Status 

Commission’s assessment  

intensifying 

regional 
Consider  also 
cooperation  arrangements  to  new  areas 
such  as  regional  generation  capacity 
assessment and research and innovation 
on technologies of common interest with 
other Member States 

Nonetheless,  compared  to  the  draft 
NECP,  France  does  not  add  more 
relevant information on cooperation with 
Portugal  and  Spain.  France  has  no 
regional 
cooperation  measures  on 
carbon  neutrality  target.  Cooperation 
with Italy on the finalisation of the NECP 
has also been very limited 

Source: European Commission (2020) Staff Working Document. Assessment of the final 
national energy and climate plan of France. 

The  Commission’s  assessment  of  France’s  draft  NECP  update  (2023)722  noted  that  it 
explains how France cooperates with other Member States within the PENTA and NSEC fora 
on  issues  such  as  security  of  supply  and  solidarity  (resource  adequacy  and  risk 
preparedness), market integration and flexibility needs, energy efficiency, decarbonisation, 
hydrogen  and  offshore  electricity.  In  the  area  of  renewable  energy,  it  refers  to  the 
cooperation on deployment of offshore wind energy and hydrogen within NSEC, including 
the identification and implementation of hybrid and joint projects. 

However,  the  assessment  highlights  that  the  NECP  does  not  provide  much  information 
about cooperation on Interconnections for South-West Europe and does not refer to recent 
initiatives within this high-level group. 

Overall, while the plan underlines that interconnections with neighbouring Member States 
have  played  a  favourable  role  in  mitigating  electricity  security  of  supply  risks,  it  also 
suggests  that  France  intends  primarily  to  rely  on  further  developing  domestic  electricity 
production capacity. France has still not signed any solidarity agreements for the security 
of gas supply out of the three needed (with Germany, Spain and Belgium). 

A5.3.5. Compliance mechanisms  

The ministry of ecological transition (in charge of energy and climate policies) has capacity 
to prepare and monitor the planning and reporting obligations set out in the Governance 
Regulation. However, in 2023, there was too much workload arising at the same time (cf. 
NECPR and draft NECP update). 

Moreover, the draft NECP update had to be prepared while the related EU legislation was 
under  revision.  This  increased  the  workload  due  to  the  negotiations,  but  also  created 
uncertainties in what should be taken into account, and how, in the draft NECP update. 

For  example,  the  guidance  on  the  draft  NECP  update  published  by  the  European 
Commission in December 2022 (2022/C 495/02) asked Member States to consider the new 
objectives set in the Fit-for-55 Package, though some of these objectives had not yet been 
adopted. Some still had not been adopted by the deadline for the draft NECP update (e.g. 
the final EED recast was adopted in July 2023). 

The  planning  documents  required  by  the  Governance  Regulation,  and  especially  the 
objectives and trajectories, need to be validated by the cabinet of the Minister of Energy. 

722 SWD(2023) 931 final. Assessment of the draft updated National Energy and Climate Plan of France. 

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Thus,  the  contents  needs  to  be  prepared  sufficiently  early  to  allow  this  process  to  take 
place. Late changes in the EU context create uncertainties and cannot be reflected.  

There has been some staff turnover in the services of the ministry. For example, none of 
the staff from the national authorities that were interviewed took part in the preparation 
and  follow  up  of  the  NECP  in  2019-2020.  They  were  therefore  unable  to  any  share 
experience  about  how  the  European  Commission’s  recommendations  on  the  first  draft 
NECP were taken into account. They also indicated that it is still too early to provide any 
feedback on the draft NECP update submitted in 2023. 

Table 48A6.9 provides a summary of the European Commission’s assessment of the draft 
updated NECP of France.  

Table 48.  European Commission’s assessment of the draft updated NECP of France 

Topic 

Summary of European Commission’s assessment (2023) 

GHG 
emission
s 

  The  draft  updated  plan  partially  embeds  the  new  and  revised  climate  targets 
included in the Fit for 55 legislative package. The plan shows concrete pathways 
to  2030  and  to  2050,  in  line  with  the  national  LTS  and  with  the  EU  climate-
neutrality objective, and including consecutive five-year carbon budgets. 

  However, the draft updated plan does not reflect the required ambition under the 
ESR, as the policies and measures in the plan narrowly do not collectively suffice 
to reach the effort sharing sector obligations (gap of 1.1% percentage point). 

LULUCF  The plan does not fully reflect the increased ambition of the LULUCF Regulation and 
in  particular  the  2030  national  target  (-34,046  Kt  CO2  eq.  in  2030  vs.  projections 
amounting to -18,000 Kt CO2 eq. by 2030 with additional measures, or -22,804 Kt 
CO2 eq. in 2030 in the scenario with existing measures). The Commission highlighted 
the need for more ambitious climate action. 

The  plan  sets  out  a  pathway  to  increase  the  contribution  of  the  land  sector  to  the 
overall EU’s enhanced climate target, but it does not quantify the mitigation potential 
of the planned measures. 

Renewa
ble 
Energy 

France’s draft updated NECP does not contain a renewable energy contribution and 
only  refers  to  the  projected  level  of  33%,  which  was  included  in  2019  NECP  to 
contribute  to  the  Union’s  32%  renewable  energy  target  for  2030.  This  level  is 
significantly  below  44%,  resulting  from  formula  in  Annex  II  of  the  Governance 
Regulation. 

The draft updated NECP does not take into account the projected shortfall to the 2020 
target  (baseline)  and  does  not  give  an  indication  of  the  policies  and  measures 
envisaged to catch up, nor does France indicate whether it intends to close this gap 
e.g., through statistical transfers or investments in the renewable energy financing 
mechanism. 

The  policies  and  measures  to  support  the  achievement  of  the  proposed  objectives 
and contributions for renewable energy include a certain level of details although a 
number of them are subject to decisions to be taken on approving the new policy. 

Energy 
Efficienc
y 

The umbrella energy efficiency targets are in line with the formula in the Annex I of 
the EED recast, and therefore reflects the revised ambition of the fit-for-55 package: 
national contribution of 157.3 Mtoe for primary energy consumption and 104 Mtoe 
for final energy consumption. 

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Topic 

Summary of European Commission’s assessment (2023) 

The draft plan provides clear and satisfactory information on the new energy savings 
requirement post-2020 under Article 7 EED (Article 8 EED recast) on energy savings 
obligation. 

However, the target on reducing total final energy consumption of all public bodies 
(Article 5 EED) is not described in the draft updated NECP. The draft stipulates that 
the definition of public bodies to determine the scope of the obligation requires further 
reflection. 

The draft plan puts forward a set of comprehensive measures addressing most of the 
relevant sectors, including building, transport and business sectors. But the draft plan 
does  not  include  estimates  of  expected  energy  savings,  apart  from  the  white 
certificates scheme (single measure reported to the energy savings obligation). 

Energy 
security 

France benefits from diversified access to natural gas and sets ambitious targets for 
renewable gases as well as for gas demand reduction.  

The  plan  emphasises  the  importance  of  developing  energy  networks  to  meet 
increasing  electricity  demand  and  the  expected  structural  changes  in  gas  and  oil 
consumption. 

However,  the  draft  plan  lacks  details  about  the  concrete  measures  to  increase  the 
French security of gas supply. 

Internal 
Energy 
Market  

France’s  draft  updated  NECP  lacks  detailed  measures  to  enhance  flexibility  in  the 
electricity  system  and  enable  a  non  discriminatory  participation  of  new  flexibility 
services. 

The  NECP  does  not  mention  any  recently  completed  or  ongoing  interconnection 
projects or an interconnectivity objective. This is announced for the final version of 
the NECP in 2024. 

Researc
h, 
innovati
on  and 
competit
iveness 

France has put in place the France 2030 Investment Plan, launched in 2021, however, 
the draft plan does not provide the detail of budget allocation from France 2030 to 
the  energy-related  priorities.  The  plan  does  not  report  on  the  national  target  and 
spending for research & Innovation (R&I) by specific clean energy technologies, nor 
does it detail the split between public and private funding. 

The investment plan focuses on five of France’s 10 strategic priorities on energy, and 
has been complemented with France 2030 Acceleration Strategies (SA). 

The  plan  does  not  explain  R&I  efforts  related  to  climate  adaptation,  carbon  sinks, 
nature restoration and air quality 

Just 
transitio
n 

France  is  developing  sectoral  action  plans  to  ensure  adequate  levels  of  skilled 
workforce to support its climate and energy transition efforts and meet skills needs 
in the new sectors. 

The draft plan states that social and economic impacts of the transition will only be 
assessed  as  part  of  the  macroeconomic  evaluation  of  the  updated  Low  Carbon 
National Strategy (SNBC 3).  

The  plan  does  not  provide  sufficient  information  for  the  preparation  of  the  Social 
Climate Plan 

Investm
ent 

The draft plan includes succinct information on additional total climate investments 
needed until 2030. A study using a net approach by estimating the difference between 

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Topic 

Summary of European Commission’s assessment (2023) 

needs, 
Policies 
and 
Measure
s 

additional  green  investments  and  the  avoided  investments  in  fossil  fuel  energy 
systems  results  in  annual  additional  investment  needs  to  achieve  France’s  energy 
and climate targets of EUR 66 billion. However, this information is insufficient. The 
draft  plan  does  not  include  a  breakdown  of  investment  needs  by  dimension  of  the 
Energy Union nor by sector. There is also no information of the investment expected 
at the level of policies and measures. The methodology is not clearly described. 

On  the  Long-Term  Strategy  (LTS),  the  assessment  conducted  for  the  European 
Commission by the consultancy Ricardo723 noted that France’s LTS set a goal in line with 
carbon neutrality by 2050, covering all main GHGs and all sectors (with the exclusion of 
international  maritime  and  aviation).  The  2030  and  2050  targets  are  both  enshrined  in 
national law. 

In general, the strategy is developed in detail and projections have been completed up to 
2050. The LTS includes one reference scenario up to 2050, including additional measures 
to meet carbon neutrality by 2050. This scenario is the one from the SNBC, resulting from 
a  stakeholder  engagement  process  (see  public  consultation  above).  The  LTS  includes 
estimations of the investments needed, amounting to EUR 3 trillion over 2019-2050. The 
socio-economic assessment is provided through an external link. 

The LTS refers to adaptation strategies through the different sections. The LTS mentions 
the  ‘Plan  national  d’adaptation  au  changement  climatique  2018-2022’  (PNACC-2). 
However, no section of the LTS covers adaptation in the 2050 context. 

In  terms  of  completeness,  the  assessment  found  that  the  LTS  includes  most  of  the 
mandatory  contents.  Gaps  in  mandatory  elements  are  about  CO2  intensity  of  GDP  and 
emission reductions and removals in the LULUCF sector. The LTS includes some of the non-
mandatory  contents  (e.g.  energy  emissions  trajectory,  expected  emission  reductions  by 
transport type and transport decarbonisation options). However, there is no information 
on  the  estimated  likely  share  of  renewable  energy  in  2050  and  little  quantitative 
information  on  energy  consumption.  One  of  the  think  tanks  interviewed  has  conducted 
research  on  the  practices  of  policy  evaluation,  and  how  evaluations  are  considered  in 
various  European  countries.  They  found  large  differences  among  countries,  which  are 
reflected in the difference in detail and quality of the LTS. There are also more differences 
in the quality of the LTSs compared to the NECPs because the template for the LTS is not 
mandatory. 

Another issue is transversality. In most of the countries analysed, the ministry in charge 
of, or leading, the planning and reporting processes under the Governance Regulation does 
not have in-house all the expertise needed (e.g. about transport and agriculture). Biomass 
is a good example  of an issue that requires a  cross-cutting approach, as it is  related at 
least to energy and agriculture, and possibly other fields. According to this think tank, the 
Governance Regulation has contributed to raising the issue of transversality (cross-cutting 
approaches)  and  coordination  between  ministries,  and  also  for  stakeholders.  As  for 
example, in France, stakeholder organisations were also structured in silos, according to 
their main contact ministry. 

A5.3.6. Lessons learnt and recommendations  

The Governance Regulation is useful, especially because it pushes the Member States to 
question their policies and planning processes, simultaneously for all policy areas relevant 
to energy and climate, therefore with more integration and coherence. As previously, for 

723 See summary table on France’s LTS: https://ec.europa.eu/clima/sites/lts/lts_fr_summary_en.pdf  

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example, the policies and planning for RES and energy efficiency were managed separately, 
both at EU and national levels. 

It also raises deeper questions, notably about what the right level of decision is according 
to  the  topic,  about  the  need  to  organise  a  more  active  planning  of  public  interventions, 
with more interactions with stakeholders. 

It  would  be  useful  to  review  the  timing  of  the  reporting  obligations,  as  well  as  the 
templates, using the experience gained about what information are the most useful and 
should be sought. 

According  to  third-sector  organisations,  the  quality  of  the  LTS  has  been  problematic, 
improvements on that side would be needed, also with more frequent revisions or updates. 
They also suggested that the coordination between Member States and joint planning need 
to be developed. For example, regional cooperation should not be focused on some RES 
projects  only  (like  offshore  wind).  The  requirements  for  regional  cooperation  could  be 
strengthened. 

The  interviewed  policy  officers  highlighted  that  the  technical  support  provided  by  the 
European Commission ahead of each reporting exercise should be continued. This has been 
very  useful  to  them.  Explaining  the  process,  sending  reminders  about  the  timeline  and 
what  needs  to  be  submitted  and  by  when,  etc.  will  also  be  useful  in  the  future.  This  is 
especially  important  because  there  can  be  turnover  in  the  teams  involved  in  preparing, 
reporting  and  submitting  the  data.  This  helps  enhance  familiarity  with  the  process  and 
understanding of how to navigate in the guidelines and the platforms. 

They also suggested that it would be useful for each Member State to receive a report that 
compiles everything that has been reported in the NECPR (and in the annual reporting), 
for tracking and monitoring. For example, because the national Court of Auditors may ask 
about  what  data  has  been  reported  to  the  EU  level.  For  the  moment,  the  exports  from 
ReportNET and ENER do not provide a complete and clear view. 

The main suggestions from the interviewed policy officers were as follows: 

  Adapt the timelines to  avoid the deadlines for  NECPR and NECP happening in the 

same year. 

  Consider adapting the timelines in case of overlaps with legislative process at EU 

level. 

  It would be useful to clarify the European Commission’s communication process (for 

the part about the complementary questions related to the NECPR).724 

  There is a need to improve the ergonomics of the platforms (ENER and ReportNET), 
especially  for  importing  and  exporting,  and  to  make  it  easier  to  review  the  data 
reported. 

  Make  sure  that  the  platforms  are  fully  operational  early  enough,  so  they  can  be 

tested at the same time as the preparatory webinars. 

724  Interviewees  from  the  National  Competent  Authority  mentioned  that  the  difficulties  to  understand 
Commission’s  questions  resulted  in  many  email  exchanges.  For  example,  some  annexes  of  the  NECPR  were 
closed, then re-opened. The status of the information (‘submitted’, ‘validated’, etc.) was not always clear, and 
the same about what was taken into account by the Commission. Some files could not be uploaded to the online 
platform, and therefore had to be submitted by email, and were not considered as official communication. 

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Table 49.  List of stakeholders consulted 

Stakeholder type 

Position/Rôle 

Interview date  

National  Competent 
Authority 

National  Competent 
Authority 

Advisor to the Director of Energy 

25 January 2024 

Project 
Efficiency Directive 

leader 

for 

the  Energy 

25 January 2024 

National  Competent 
Authority 

Policy  officer  for  climate  strategy 
for organizations and climate policy 
reporting 

25 January 2024 

Third-sector 
organisation 
tank) 

Third-sector 
organisation 
tank) 

(Think 

Head  of  European  policies,  Expert 
on energy and climate 

10 January 2024 

(Think 

Program Director for Steering tools 
and financing the transition 

24 January 2024 

Third-sector 
organisation (NGO) 

Head of programmes 

26 January 2024 

Third-sector 
organisation (NGO) 

European  relations  and  policies 
manager 

26 January 2024 

Table 50.  Documents reviewed  

Document type 

Author(s) and title 

Year 

Draft NECP 

NECP 

Ministry  of  Ecological  Transition:  « Projet  de  Plan 
National Intégré Energie-Climat de la France » 

January 
2019 

Ministry  of  Ecological  Transition:  « Plan  National 
Intégré Energie-Climat de la France » 

March 
2020 

Draft NECP update 

Ministry  of  Ecological  Transition:  “National  Energy 
Climate-Plan of France – Draft Update” 

October 
2023 

LTS 

Ministry of Ecological Transition: « Stratégie Nationale 
Bas Carbone » 

March 
2020 

Commission 
Recommendation  on 
draft NECP 

Commission Recommendation of 18 June 2019 on the 
draft integrated National Energy and Climate Plan of 
France  covering  the  period  2021-2030  (and  related 
SWD) 

June 
2019 

Commission 
Assessment  on  final 
NECP 

October 
2020 

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Document type 

Author(s) and title 

Year 

Commission 
Recommendation  on 
draft NECP 

Commission  Recommendation,  Assessment  (SWD) 
and  Factsheet  of  the  draft  updated  National  Energy 
and Climate Plan of France 

Decembe
r 2023 

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A5.4. Case Study – Germany 

A5.4.1. Background  

In Germany, the energy transition and environment protection are implemented at Federal 
Government level, individual Land (state) level and municipal level.  

At  Federal  level,  the  Federal  Ministry  for  Economic  Affairs  and  Climate  Action  (BMWK) 
guides energy policy, while the Federal Ministry for the Environment, Nature Conservation 
and Nuclear Safety (BMUV) is competent on climate policy. 

The Federal Government and the Länder (states) regularly coordinate their activities while 
implementing the energy transition. In a half-year cycle, meetings are held between the 
Federal Chancellor and the heads of government of the Länder. The Federal Ministers with 
relevant subject-area competence also take part. In these meetings, they also discuss the 
degree  to  which  the  energy  transition  has  been  implemented.    Relevant  ministers  at 
Federal and at Land level also consult each other annually, in the conferences of Federal 
and  Land  ministers  of  economic  and  environmental  affairs,  respectively,  clarifying  their 
priorities and coordinating the next steps in the energy transition process. This institutional 
coordination is reinforced by topic-specific, management-level discussions and also by an 
ongoing cooperation and frequent exchange of inputs among experts.725 

German NECP, NECPRs and LTS 

Germany  notified  the  European  Commission  of  its  draft  integrated  National  Energy  and 
Climate Plan (NECP) on 20 December 2018,726 prior to the deadline set in Article 9 of the 
Governance Regulation (namely, 31 December 2018).  

In  June  2019,  the  European  Commission  published  an  assessment  and  country-specific 
recommendations  to  all  Member  States  on  their  draft  NECPs.727  Taking  these 
recommendations into account, Member States were required to submit their final NECPs 
by 31 December 2019. Germany notified its final NECP to the European Commission on 11 
June  2020  (hence,  with  a  six-months  delay).728    In  October  2020,  the  Commission 
published its assessment of the German final NECP.729  

By 30 June 2023, Member States were due to submit their draft updated NECPs, as per 
Article 14 of the Governance Regulation. Germany submitted its draft updated NECP more 
than three months after the deadline, in November 2023.730  

Additionally,  the  Governance  Regulation  required  Member  States  to  submit  their  first 
national long-term strategies (LTS) to the Commission by 1 January 2020. The German 
LTS, submitted to the Commission in January 2020, was prepared in 2016. However, in 
2019,  the  Federal  Climate  Change  Act  entered  into  force  in  Germany.  This  was 

725 Federal Ministry for Economic Affairs and Energy (2018) Draft of the Integrated National Energy and Climate 
Plan.  
726 Federal Ministry for Economic Affairs and Energy (2018) Draft of the Integrated National Energy and Climate 
Plan. Available here: https://energy.ec.europa.eu/system/files/2019-03/ger_draft_necp_eng_0.pdf 
727  European  Commission  (2019)  Staff  Working  Document.  Assessment  of  the  draft  NECP.  Available  here: 
de_swd_en_0.pdf (europa.eu)  
728 Federal Ministry for Economic Affairs and Energy (nd) Integrated National Energy and Climate Plan. Available 
here: de_final_necp_main_en.pdf (europa.eu)  
729 European Commission (2020) Staff Working Document. Assessment on the final national energy and climate 
plan of Germany. Available here: staff_working_document_assessment_necp_germany_en_0.pdf (europa.eu)  
730 European Commission (2023) Staff Working Document. Assessment on the draft updated national energy and 
climate  plan  of  Germany.  Available  here:  SWD_Assessment_draft_updated_NECP_Germany_2023.pdf 
(europa.eu)  

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subsequently  amended  in  July  2021.  Hence,  the  assessment  of  the  national  LTS 731 
underlines that Germany’s LTS is outdated and does not reflect Germany’s current legal 
commitments on climate and energy policies.732  

Germany’s  key  objectives,  targets  and  contributions  as  per  Germany’s  draft 

updated NECP 

Figure 57A6.3 provides an overview of the key climate and energy objectives, targets and 
contributions, as outlined in Germany’s 2023 draft updated NECP.  

Figure 57. Germany’s key objectives, targets and contributions 

Source:  European  Commission  (2023)  Factsheet:  Germany’s  draft  updated  National 
Energy and Climate Plan733 

A5.4.2. Main costs and benefits of the Governance Regulation  

This section is primarily informed by data and feedback provided by stakeholders that are 
mandated  to  comply  with  the  Governance  Regulation’s  reporting  obligations.  It  aims  to 
provide an overview of the main costs and benefits associated with the compliance with 
selected obligations stemming from the Governance Regulation.  

Main Costs 

The interviewed stakeholders are competent to collect information on GHG policies and 
measures  and  on  projections  (Article  18  of  the  Governance  Regulation),  national 
adaptation actions (Article 19 of the Governance Regulation), renewable energy (Article 
20 of the Governance Regulation), to be included in the NECPR. They are also competent 
for the drafting of the NECP and the NECPR.  

Numerous human resources are involved in the collection of information for the purpose of 
drafting the German NECP and NECPRs. Within the federal ministry competent for drafting 

731 Provided by the consultancy Ricardo (as part of a contract to support DG CLIMA with the assessment of the 
LTSs). Ricardo Energy & Environment . Assessment of the Long-Term-Strategies of EU Member States. Germany. 
Available here: https://ec.europa.eu/clima/sites/lts/lts_de_summary_en.pdf   
732 Ricardo  Energy  &  Environment  . Assessment of  the  Long-Term-Strategies of  EU Member  States.  Germany. 
Available here: https://ec.europa.eu/clima/sites/lts/lts_de_summary_en.pdf  
733 Available here: Factsheet_Commissions_assessment_NECP_Germany_2023.pdf (europa.eu)  

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the NECP and NECPR there are approximately three staff, though the drafting of the NECP 
and  NECPRs  does  not  represent  their  only  responsibility.734  The  unit  is  responsible  for 
collecting  the  information  as  input  to  the  NECP  and  NECPR,  which  is  done  by  different 
authorities.  For  this  reason,  the  interviewed  stakeholders  were  not  able  to  quantify  the 
costs associated with the reporting obligations.  

In  relation  to  the  reporting  on  Article  18  (on  integrated  reporting  on  greenhouse  gas 
policies  and  measures  and  projections),  one  interviewed  stakeholder  mentioned  the 
following associated costs: 735  

  Number  of  stakeholders  involved:  the  unit  responsible  for  reporting  on  GHG 

policies, measures and projections is relatively small (around three people). 

  Main external costs: the competent unit outsources the screening of GHG policies, 
measures  and  the  modelling  of  GHG  projections  to  two  research  institutes.  The 
competent  unit  did  not  disclose  the  magnitude/financial  details  of  these  external 
contracts, due to confidentiality reasons.  

  Other  internal  costs:  the  competent  unit  also  acts  as  a  bridge  between  the 
research institute  and the Quality Assurance process, to make sure that the data 
provided aligns with that requested by EU level obligations. Other costs relate to the 
internal coordination that the unit needs to ensure with other stakeholders, such as 
other  agencies  that  are  responsible  to  produce  Land  Use,  Land  Use  Change  and 
Forestry  (LULUCF)  and  agricultural  projections,  that  are  linked  to  the  German 
Ministry of Agriculture.   

As  regards  reporting  on  Article  19(1)  (on  integrated  reporting  on  national  adaptation 
actions), the interviewed stakeholder reported the following associated costs:736 

  Number  of  stakeholders  involved:  a  unit  of  around  10  people  is  involved  in 
collecting,  checking,  and  inputting  information  and  data  in  ReportNET3  for  the 
purpose  of  reporting on Article 19.  This is done through collecting already  signed 
off/finalised reports from different authorities (from different German states), and 
potential additional exchanges when more information is needed.  

  Main  internal  costs:  The  national  process  already  required  the  same  exercise. 
Hence,  the  Governance  Regulation  did  not  cause  any  additional  burden,  except 
inputting  information  on  ReportNET  3  in  a  slightly  different  format.  However,  the 
two-year  reporting  period  mandated  by  Article  19  of  the  Governance  Regulation 
does  not  align  with  the  four-year  reporting  cycle  established  at  national  level. 
Consequently,  the  German  Environment  Agency  is  not  always  able  to  provide 
updated  information  and  data  every  two  years.  Additionally,  according  to  the 
interviewed stakeholder, the need for occasional adjustments due to word limits in 
the  reporting  platform  sometimes  leads  to  a  several  iterative  exchanges  with 
different authorities that need to check the data to be submitted.  

Main benefits  

On the benefits related to the implementation of the Governance Regulation, interviewed 
stakeholders mentioned the following aspects: 

  Better  established  processes:  although  interviewed  stakeholders  were  not 
knowledgeable  about  the  situation  prior  to  the  adoption  of  the  Governance 
Regulation, one  stakeholder competent for Article 18 related reporting underlined 
that the deadline of 15 March mandated by the Governance Regulation enhanced 
the streamlining of their internal working processes (i.e., enhancing productivity to 

734 Interview with national authority conducted on 15/02/2024  
735 Interview with national authority conducted on 17/01/2024.  
736 Interview with national authority conducted on 19/01/2024.  

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meet the deadline). Although some challenges persist, the interviewed stakeholder 
did not view the Governance Regulation as the driver of such challenges, with these 
being  more  related  to  internal  processes  and  division  of  responsibilities  within 
Germany. 737    Additionally,  two  stakeholders  underlined  that  the  benefits  of  the 
Governance Regulation may not be completely visible yet given that the first years 
of  implementation  involved  a  learning  curve  for  national  competent  authorities, 
which are now more familiar with the different processes. 738 

  EU-level support. Two national authorities mentioned that the guidance provided 
by the European Commission and the European Environmental Agency, particularly 
through  dedicated  workshops  and  tailored  feedback,  was  particularly  useful  to 
ensure  effective  compliance  with  the  reporting  obligations.739  One  authority 
mentioned that the ClimateAdapt website is a useful repository of data on Article 19 
related  reporting.740  However,  two  stakeholders  mentioned  that  additional  (more 
targeted)  guidance  would  be  beneficial,741  with  one  of  them  underlining  that  the 
guidance arrived very late when compared to the deadline.742  

  Enhanced  transparency  and  better  information  on  the  Energy  Union 
dimensions. Three interviewed stakeholders (two national authorities and an NGO) 
mentioned  that  the  Governance  Regulation  brought  increased  transparency  and 
increased  information  on  the  Energy  Union  dimensions.743  However,  national 
authority  mentioned  that  transparency  could  be  enhanced:  for  instance,  when  it 
comes  to  where  the  information  is  published.744  Another  national  authority 
underlined  that  NECPRS  are  very  technical  and  difficult  to  understand  for  a  non-
expert audience.745 

Consulted  stakeholders  also  mentioned  some  “unexploited  potential  benefits”  related  to 
the implementation of the Governance Regulation. These are detailed below:  

  Enhanced sharing of information and best practices among Member States. 
One  national  authority  underlined  that  the  current  systems  fail  to  provide  user-
friendly  access  to  data  reported  by  other  Member  States  on  Article  18  related 
reporting.746 Another added that additional, more targeted, guidance (and sharing 
of best practices, “do’s and don’ts”)  would be beneficial, such as through dedicated 
webinars.747  

  Limited importance given to the Governance Regulation (and its outputs) 
in  Germany.  Three  consulted  stakeholders  mentioned  that  the  Governance 
Regulation  has  not  been  given  attention  in  Germany.748  For  instance,  they 
mentioned that compiling NECPs is seen merely as a box-ticking exercise. The fact 

737 Interview with national authority conducted on 17/01/2024.  
738 Interview with national authority conducted on 15/02/2024; Interview with national authority conducted on 
15/02/2025  
739 Interviews with national authorities conducted on 17/01/2024 and on 19/01/2024. 
740 Interview with national authority conducted on 19/01/2024.  
741 Interview with national authority conducted on 15/02/2024; Interview with national authority conducted on 
15/02/2024 
742 Interview with national authority conducted on 15/02/2024 
743 Interview with national authority conducted on 17/01/2024; Interview with NGO (conducted on 22/01/2024); 
Interview with national authority conducted on 15/02/2024 
744 Interview with national authority conducted on 15/02/2024.  
745 Interview with national authority conducted on 15/02/2024 
746 Interview with national authority conducted on 17/01/2024.  
747 Interview with national authority conducted on 19/01/2024.  
748  Interview  with  academic  (conducted  on  19/01/2024);  interview  with  NGO  (conducted  on  22/01/2024); 
Interview with think tank (conducted on 22/01/2024) 

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that the LTS dates to 2016 (before important EU and national level developments 
occurred)  also  shows  the  limited  attention  given  to  the  Governance  Regulation 
related obligations. Nevertheless, two national authorities mentioned that the low 
importance given to the Governance Regulation in Germany may be explained by 
the fact similar obligations already existed at national level (for data collection and 
public consultation purposes),749 and at EU level (i.e., reporting to Eurostat).  

A5.4.3. Public consultation and multilevel climate and energy dialogues  

This section outlines Germany’s compliance with the obligations laid down in Article 10 (on 
public  consultation)  and  Article  11  (on  multilevel  climate  and  energy  dialogues)  of  the 
Governance Regulation.  

Public consultation 

Article 10 of the Governance Regulation requires the Member States to ensure that the 
public is given early and effective opportunities to participate in the preparation of the draft 
NECPs and LTS. It also specifies that each Member State must set reasonable timeframes 
allowing sufficient time for the public to be informed, to participate and express its views.  

Evidence  shows that for the German 2050 Climate Action Plan, stakeholder  consultation 
was  extensive,  taking  place  over  the  course  of  more  than  one  year  through  different 
formats and phases.750 However, a consultation for the draft NECP did not take place. 751 
The European Commission’s 2019 assessment of Germany’s draft NECP explains that public 
consultation  on  the  draft  plan  had  recently  started,  and  that  further  consultations  were 
planned during 2019.752 

Germany’s final NECP provides a detailed overview of the responses received as 
part  of  the  public  consultation.753  The  public  consultation  was  conducted  online 
between  14  June  and  2  August  2019,  and  200  responses  were  received  as  part  of  this 
process.  Respondents  included,  among  others,  private  individuals,  companies,  industrial 
associations,  NGOs/civil  society  organisations,  academics/research  institutions,  federal 
authorities, and foundations.  

As regards the extent to which the comments provided by stakeholders were addressed, 
the final NECP provides that “in the second half of 2019, numerous points of criticism from 
the  responses  were  addressed,  in  particular  as  part  of  the  implementation  of  the 
recommendations of the Commission on Growth, Structural Change and Employment and 
of  the  Climate  Cabinet  process.  This  is  illustrated  in  the  NECP”.754  The  European 
Commission’s assessment explains that, although Germany submitted a detailed summary 
and analysis of the public’s views on the draft plan for each of the energy union dimensions, 
the plan does not always clarify how these views were taken into account.755  

The 2023 draft updated NECP did not outline a procedure to ensure early public 
participation. The plan only explains that consultations will take place during the 2023-
2024  period,  and  that  the  Federal  Ministry  of  Economic  Affairs  and  Climate  Protection 

749 Interview with national authority conducted on 15/02/2024; Interview with national authority conducted on 
15/02/2024 
750 LIFE PlanUP (2019) Report on Good Practices in Energy and Climate Governance  
751 European Commission (2023) Local and regional authorities in the governance of the energy union 
752 European Commission (2019) Assessment of the draft NECP of Germany.  
753  German  final  integrated  National  Energy  and  Climate  Plan.  Available  here:  de_final_necp_main_en.pdf 
(europa.eu)  
754 German final integrated National Energy and Climate Plan 
755 staff_working_document_assessment_necp_germany_en_0.pdf (europa.eu)  

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provides information on the NECP process and opportunities for participation in the planned 
consultations on its website.756 

Three consulted stakeholders underlined that, in the past, public consultation on the NECPs 
has  been  insufficient  in  Germany.757  They  also  agreed  that  meaningful  stakeholder 
engagement is beneficial, as it might promote ownership of the plans and strategies.  

One consulted national authority explained that, in Germany, the public consultation that 
is carried out for the purpose of Article 10 of the Governance Regulation is not intended to 
gather  feedback  on  specific  policies  or  measures.758  This  is  because  more  ad  hoc 
consultations  already  took  place  when  the  legislative  processes  started  and  led  to  the 
adoption  of  such  policies  or  measures.  In  other  words,  the  public  consultation  primarily 
intends to gather feedback on the NECP, which is a collection of policies and measures that 
are already in place. Hence, the aim of the consultation is to collect insights on whether 
the  NECP  shows  a  good  balance,  in  terms  of  different  dimensions  and  topics,  among 
different policies and measures, but will not lead to any substantial change of the policies 
and  measures  included  in  the  plan.  The  consulted  stakeholder  underlined  that,  in  this 
sense, the Governance Regulation is not particularly fitting the German situation, but that 
it is intended more as an overarching consultation on the NECP.   

On 24 January 2024, the Federal Ministry for Economic Affairs and Climate Action 
launched a public consultation, in the form of an online survey, which will be open until 
16 March 2024.759 The online survey covers questions on all five Energy Union dimensions 
and  asks  for  written  feedback  (albeit  with  a  400-digit  limit)  to  respondents.  One 
interviewed  stakeholder  mentioned  that,  as  of  15  February  2024,  the  number  of  replies 
was relatively low. To address this, the competent authority is trying to advertise the public 
consultation more broadly (e.g., through regular newsletters). 760  

Multi-level climate and energy dialogues 

Article  11  of  the  Governance  Regulation  requires  the  Member  States  to  establish  a 
multilevel climate and energy dialogue (MLCED) pursuant to national rules, in which local 
authorities, civil society organizations, business community, investors and other relevant 
stakeholders  and  the  general  public  are  able  to  engage  actively  and  discuss  the 
achievement of the Union’s climate-neutrality objective set out in Article 2(1) of Regulation 
(EU)  2021/1119  and  the  different  scenarios  envisaged  for  energy  and  climate  policies, 
including for the long term, and review progress, unless it already has a structure which 
serves the same purpose. NECPs may be discussed within the framework of such dialogues.  

The  European  Commission’s  assessment  of  Germany’s  final  NECP  invited  Germany  to 
“unlock  the  potential  of  multilevel  climate  and  energy  dialogues  to  actively  engage  with 
regional  and  local  authorities,  social  partners,  civil  society  organisations,  business 
community,  investors  and  other  stakeholders  and  to  discuss  with  them  the  different 
scenarios envisaged for its energy and climate policies”. 761 

Evidence  shows  that  no  ad  hoc  MLCED  has  taken  place  in  Germany.762  This  is 
because structures that serve the same purpose already existed. Such structures 

756 European Commission (2023) Assessment of the draft updated integrated national energy and climate plan of 
Germany. Available here: SWD_Assessment_draft_updated_NECP_Germany_2023.pdf (europa.eu) 
757 Interview with academic, Interview with think tank, Interview with NGO 
758 Interview with national authority conducted on 15/02/2024 
759 BMWK – National Energy and Climate Plan (NECP)  
760 Interview with national authority conducted on 15/02/2024 
761 European Commission (2020) Staff Working Document. Assessment of the final national energy and climate 
plan of Germany. Available here: adf16801-039d-422b-9f3f-8d8be0dd732e_en (europa.eu)  
762  CAN  Europe;  WWF  (2023)  Public  participation  in  national  energy  and  climate  plans.  Evidence  of  weak  and 
uneven compliance in Member States  

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usually  take  the  form  of  roundtables  or  working  groups  on  specific  topics  with  specific 
stakeholders. Specifically, the German progress report (particularly, its Annex XXIII on 
MLCEDs)763  lists  several  existing  platforms  in  Germany  that  serve  for  stakeholder 
dialogues.  The  Annex  provides  that  “Germany  maintains  a  range  of  climate  and  energy 
dialogues”. 764 The box below presents such  existing platforms/fora listed in the  German 
progress report.  

  Stakeholders’ dialogue platforms on climate and energy in Germany 
  Energy transition platforms serve as a forum for stakeholders to take stock of 

the transition process and to identify regulatory needs.  

  Energy Efficiency Platform: in 2014 the Federal Ministry for Economic Affairs 
and  Energy  launched  a  dialogue  platform  to  discuss  the  government’s  energy 
efficiency  measures  with  all  relevant  stakeholders.  This  includes  stakeholders 
from  industry,  civil  society,  science,  the  relevant  departments  and  the  federal 
states  who  develop  new  tools  and  explore  how  to  improve  market  and  policy 
conditions.  The  Platform  is  the  central  dialogue  forum  for  the  German 
government’s  Energy  Efficiency  2045  Roadmap.  The  aim  is  to  develop  suitable 
strategies for increasing energy efficiency in a broad discourse with stakeholders 
with the perspectives 2030 and 2045. Plenary sessions take place once a year, 
prepared by thematic working groups which include energy efficiency in industry, 
buildings, mobility, qualification, digitalisation, and cross-cutting issues. The work 
of  the  platform  will  continue  in  a  reduced  scope  with  more  ad-hoc-themed 
gatherings. 

  Platform Climate Neutral Power System: multiple plenary and working group 
meetings with stakeholders from industry associations, research, and society to 
discuss market design options for a largely renewable electricity system. 

  Energy Transition Research and Innovation Platform: acts as an advisory 
body  for  overarching  issues  concerning  funding  policy  in  energy  research. 
Members of the platform include authorities, representatives of the energy sector, 
research institutes, and social institutions.  

  In  addition,  participatory  processes  are  organised  in  the  course  of  preparing 
federal laws and regulations, or government strategies. For instance, Germany is 
currently 
strategy 
(Systementwicklungsstrategie)  in  close  cooperation  with  stakeholders  from  the 
energy sector, industry, and civil society. The stakeholder forum convenes at least 
quarterly to deliberate a shared vision of the future energy system. 

development 

developing 

system 

a 

  Alliance  for  Climate  Action:  the  Alliance  was  set  up  in  2015  and  was  active 
until  2021.  Business  associations,  representatives  of  civil  society,  the  social 
sector, scientific institutions, federal states, municipalities associations and youth 
organisations met twice a year in a plenary session to review progress on national 
climate  policy  and  exchange  views  on  climate  action.  The  Alliance  for  Climate 
Action  was  evaluated  in  2021.  As  a  main  conclusion,  participants  did  not  see 
added  value  in  the  Alliance,  compared  to  other  existing  dialog  platforms. 
Consequently, the Alliance for Climate Action was discontinued.  

763 Member States had to submit dedicated reports on the implementation of MLCEDs for the first time in 2023. 
The  implementing  regulation  ((EU)2022/2299)  lays  down  details  for  the  progress  reports,  requiring  Member 
States to spell out details on how it is implementing the obligation to carry out the dialogues (as per its Annex 
XXIII). Commission  

Implementing  Regulation  (EU)  2022/2299  of  15  November  2022  laying  down  rules  for  the  application  of 
Regulation  (EU)  2018/1999  of  the  European  Parliament  and  of  the  Council  as  regards  the  structure,  format, 
technical details and process for the integrated national energy and climate progress reports  
764 The German progress report (including its Annex XXIII) is available on the CIRCABC platform.  

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Although two consulted stakeholders reported that platforms for stakeholder dialogues on 
climate  and  energy  policy  exist  in  Germany,  they  could  not  link  such  platforms  to  the 
Governance Regulation’s related obligations and were uncertain about their “multi-level” 
nature.765  

A5.4.4. Regional cooperation 

Article  12  of  the  Governance  Regulation  requires  the  Member  States  to  cooperate  with 
each other, considering all existing and potential forms of regional cooperation, to meet 
the objectives, targets, and contributions set out in the integrated NECP effectively.  

Overall,  Germany  cooperated  with  other  Member  States  (mainly,  its  neighbouring 
countries)  both  bilaterally  and  within  multilateral  forums.  However,  it  is  not  possible  to 
ascertain  whether  regional  cooperation  could  be  associated  with  the  Governance 
Regulation,  given  that  stakeholders  could  not  link  Germany’s  cooperation  with  other 
countries  to  the  obligations  imposed  by  the  Regulation,  and  because  Germany’s 
cooperation with neighbouring countries took place even before the Governance Regulation 
entered into force.  

The first draft NECP of Germany describes the regional cooperation activities in 
which  Germany  participated.766  These  took  the  form  of  bilateral  cooperation  (e.g., 
France  and  Belgium)  or  joint  initiatives  and  forums  involving  multiple  Member  States 
(multilateral cooperation). Multilateral cooperation initiatives included  cooperation within 
the European Climate Initiative, the Baltic Energy Market Interconnection Plan, the North 
Sea Energy Forum, the Pentalateral Energy Forum, the Pentalateral Gas Forum, and the 
cooperation in regional groups in the context of the trans-European energy networks.  

In  its  assessment  of  the  draft  NECP  of  Germany,  the  European  Commission 
identified good practice examples of cross-border cooperation.767 Specifically, the 
European Commission’s assessment refers to Germany’s membership of the Pentalateral 
Energy Forum, and Germany’s contribution to the European Climate Initiatives, which aims 
at fostering cross-border dialogue and cooperation as well as exchange of knowledge and 
experience  on climate  policies within the EU.  The European Commission underlined that 
setting up a dedicated Committee to coordinate regional cooperation on the draft NECPs 
within the context of the Pentalateral Energy Forum could be regarded as a good practice 
that can inspire other Member States. In its recommendations, the European Commission 
encouraged  Germany  to  continue  regional  cooperation  efforts  in  respective  high-level 
groups and consultation of neighbouring Member States.768 

Germany’s  final  NECP  also  refers  to  several  initiatives  promoting  regional 
cooperation,  particularly  the  Pentalateral  Energy  Forum  and  the  North  Seas  Energy 
Cooperation  (NSEC).769  It  states  that  the  success  achieved  over  the  last  15  years  is 
demonstrated by the outlook of each of the countries involved in the Pentalateral Energy 
Forum, in terms of their energy policy, developing from one with a purely national focus to 
one with a truly regional approach.  

765 Interview with think tank conducted on 22/01/2024; Interview with academic conducted on 19/01/2024 
766 Federal Ministry for Economic Affairs and Energy. Draft of the Integrated National Energy and Climate Plan. 
Wirtschaftsmotor Mittelstand – Zahlen und Fakten zu den deutschen KMU (europa.eu)  
767 European Commission (2019) Commission Staff Working Document. Assessment of the draft integrated NECP 
of  Germany.  Available  here:  https://energy.ec.europa.eu/document/download/93ef4da6-e69c-47ed-8f26-
c4e84e9102eb_en 
768 European Commission (2019) Recommendation on the draft integrated National Energy and Climate Plan of 
Germany covering the period 2021-2030. 229 final  
769  Federal  Ministry  for  Economic  Affairs  and  Energy.  Integrated  National  Energy  and  Climate  Plan. 
https://energy.ec.europa.eu/system/files/2022-08/de_final_necp_main_en.pdf 

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In its assessment of the final NECP of Germany, the European Commission found that 
the  recommendations  on  regional  cooperation  based  on  the  draft  NECP  have  been  fully 
addressed by Germany in its final NECP, 770 as described in A5.4.4.   

Table 51.  European  Commission  assessment  of  the  final  NECP  of  Germany:  regional 

cooperation  

Recommendation 
cooperation 

on 

regional 

Status 

Commission’s assessment  

Continue,  both  in  the  finalisation  of  the 
integrated  national  energy  and  climate 
plan  and  during  its  implementation, 
regional  cooperation  in  respective  high-
level  groups  and 
consultation  of 
neighbouring Member States. 

Fully 
addresse
d 

phase-out, 

In  that  context,  focus  on  the  coal  and 
lignite 
renewables 
deployment  and  the  internal  energy 
issues  such  as 
market,  addressing 
interconnection levels and capacity  

Fully 
addresse
d 

from 2021 onwards, regional cooperation 
measures  related  to  assessing  system 
adequacy,  just  transition  and  energy 
for 
system 
accommodating 
of 
renewables  that  are  expected  to  modify 
trade  while 
cross-border  electricity 
enhancing the need for system flexibility.  

required 

changes 

shares 

higher 

and 

energy 

climate 

Germany received a recommendation to 
reinforce  regional  cooperation  and  it 
fully  addressed  this  recommendation. 
Specifically,  Germany  engaged  in  a 
number of regional cooperation settings, 
which are listed and briefly described in 
the  final  plan.  This  includes  multi-
faceted bilateral cooperation with France 
on 
policy, 
declarations  of  intent  with  Belgium  and 
the Netherlands, and aspects of  energy 
and climate policy in the context of the 
strategic  dialogue  with  Czechia.  It  also 
includes  multilateral  cooperation  in  the 
the  European  Climate 
context  of 
Initiative  (EUKI),  the  Baltic  Energy 
Market  Interconnection  Plan,  the  North 
Seas  Energy  Forum,  the  Pentalateral 
Energy Forum, and the Pentalateral Gas 
Forum  on  issues  ranging  from  market 
coupling, maritime  spatial planning and 
offshore renewable energy.  

The final plan details the contacts of the 
German administration with  

their  counterparts  on  phasing  out  coal 
and  lignite  in  a  regional  setting.  The 
other  topics  are  all  addressed  in  these 
fora for cooperation. 

Source: European Commission (2020) Staff Working Document. Assessment of the final 
national energy and climate plan of Germany. Annex  

770 European Commission (2020) Commission Staff Working Document. Assessment of the final national energy 
and climate plan of Germany. adf16801-039d-422b-9f3f-8d8be0dd732e_en (europa.eu)  

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The  European  Commission’s  assessment  of  the  German  draft  updated  NECP  (2023) 
identifies various consultations that have taken place with neighbouring countries.771 These 
took place bilaterally with Denmark, Austria, and Czechia, as well as in established fora, 
including  the  Pentalateral  Forum  and  the  NSEC.  The  collaboration  mainly  focused  on 
electricity markets, security of supply, flexibility, energy efficiency and decarbonisation, as 
reflected  in  the  joint  NECP  chapter  of  the  Pentalateral  Forum,  and  the  accelerated 
deployment of offshore renewables as reflected in the joint NECP chapter of NSEC covering 
joint/hybrid  projects,  permitting/maritime  spatial  planning,  financing  and  long-term 
infrastructure planning. 

Consulted  stakeholders  confirmed  that  Germany  cooperated  with  other  Member  States, 
both  bilaterally  and  within  regional  fora. 772  Nevertheless,  they  underlined  that  Germany 
could  further  enhance  regional  cooperation  efforts.  For  instance,  one  stakeholder 
underlined that, in the context of German French cooperation, the so-called Meseberger 
Klima-AG  (which  brings  together  all  German  and  French  ministries  relevant  to  climate 
policy) has not been convened since 2021, representing a missed opportunity.773  

A5.4.5. Compliance mechanisms  

This section provides an overview of Germany’s progress towards addressing the European 
Commission’s recommendations provided on the first draft NECP, and the overall quality 
of the German’s draft updated NECP and its LTS.  

In June 2019, the European Commission issued 11 recommendations to Germany, 
based on its draft NECP.774 The Commission’s assessment of the final NECP split these 
11 recommendations into 22 more detailed recommendations.  

its 

final  NECP,  Germany  addressed 

In 
the  European  Commission’s 
recommendations,  with  room  for  improvement,  with  11  recommendations  either  fully 
(4) or largely (7) addressed and 9 partially addressed.  

Figure 58. Status of Commission’s recommendations following the submission of German 

final NECP (n=22) 

771 European Commission (2023) Commission Staff Working Document. Assessment of the draft updated National 
Energy and Climate Plan of Germany. 8bc322cc-f9b3-466d-99f7-ef201a8a3d1c_en (europa.eu)  
772  Interview with  national  authority  (German  Environment  Agency)  conducted  on 17/01/2024;  Interview  with 
academic conducted on 19/01/2024; Interview with national authority (Federal Ministry for Economic Affairs and 
climate action) conducted on 15/02/2024 
773 Interview with NGO conducted on 22/01/2024.  
774 European Commission (2019) Recommendation on the draft integrated NECP of Germany covering the period 
2021-2030. C(2019)4405.pdf  

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Source: ICF elaboration, based on European Commission (2020) Staff Working Document. 
Assessment of the final NECP of Germany, Annex.  

According to  one national authority, the European Commission’s recommendations were 
not  unexpected  from  a  substantial  point  of  view,  given  they  were  already  aware  of  the 
main weaknesses of the NECP.775  

Germany’s  2023  draft  updated  NECP  refers  to  the  revised  energy  and  climate  targets 
recently  agreed  under  the  Fit  for  55  package  and  the  REPowerEU  Plan.  However,  the 
European Commission’s assessment explains that it does not sufficiently elaborate on how 
these  targets  will  be  achieved.776  Although  the  plan  is  not  complete,  it  followed  the 
template provided by Annex I of the Governance Regulation, covering all five dimensions, 
and including the main objectives and targets. Table 48A6.13 provides a summary of the 
Commission’s assessment of the draft updated NECP of Germany.  

Table 52.  European Commission’s assessment of the draft updated NECP of Germany 

Topic 

Summary of European Commission’s assessment (2023) 

GHG 
emissions 

  The  plan  provides  emission  projections  demonstrating  that  with  existing 
policies and measures Germany is not on track to meet its national greenhouse 
gas target of -50% in 2030 compared to 2005 levels. 

  According to Germany’s projections, there is a gap of 15.4 percentage points, 

highlighting the need for more ambitious climate action.  

LULUCF 

The draft updated plan indicates that Germany will not meet its 2030 target.  

However,  when  taking  into  account  the  latest  revised  inventory  data,  Germany 
appears to be on track, thus making a full assessment of the EU target complex. 

The draft does not provide a clear implementation timeframe, nor a quantification 
of the impacts of specific policies and measures. 

Renewable 
Energy 

Germany’s draft updated NECP presents a contribution to the overall EU target of 
40%  of  renewables  in  national  gross  final  energy  consumption.  This  is  slightly 
below the share of 41% resulting from the formula in Annex II of the Governance 
Regulation 

Energy 
Efficiency 

On  Energy  Efficiency,  the  German  draft  updated  NECP  is  comprehensive, 
ambitious, informative, and detailed. 

The  increased  ambition  in  Directive  (EU)  2023/1791  on  energy  efficiency  and 
amending Regulation (EU) 2023/955 (‘EED recast’) has been taken into account, 
in  particular  for  the  2030  energy  efficiency  targets,  as  well  as  for  the  energy 
savings  obligation.  It  includes  national  contributions  to  the  EU’s  2030  energy 
efficiency targets of 160.5 Mtoe for final energy consumption, and of 193.6 Mtoe 
for primary energy consumption with measures covering a wide range of demand 
sectors. 

The  Energy  Efficiency  First  principle  is  mentioned  as  the  basis  for  planning 
considerations  but  it  is  still  needs  to  be  spelled  out  in  terms  of  policies  and 
measures 

775  Interview  with  national  authority  (Federal  Ministry  for  Economic  Affairs  and  Climate  Action)  conducted  on 
15/02/2024 
776 European Commission (2023) Staff Working Document. Assessment of the draft updated NECP of Germany. 
SWD_Assessment_draft_updated_NECP_Germany_2023.pdf (europa.eu)  

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Topic 

Summary of European Commission’s assessment (2023) 

The draft updated NECP puts forward a set of comprehensive planned measures 
addressing  all  sectors,  including  buildings,  transport  and  business  sectors. 
However, a sufficient level of detail on expected savings such as the contribution 
to the energy saving obligations and the energy efficiency targets is not provided 
and  the  information  on  the  public  sector  obligations  is  missing  as  well  as 
information on financial needs and funding sources. 

Energy 
security 

In the gas sector, the plan highlights the measures that have allowed Germany to 
compensate  for  the  declining  gas  flows  from  Russia  and  thereby  significantly 
reduce its dependence on Russia. The draft updated NECP does not envisage any 
additional objectives to further diversify gas supply.  

The  plan  lacks  a  clear  description  of  the  implemented  gas  demand  reduction 
measures and how these measures are integrated in the medium-term planning 
towards 2030. 

Internal 
Energy 
Market  

The draft updated NECP sets out on-going and planned reinforcements of the grid 
infrastructure  both  internally  and  with  neighbouring  countries.  While  the  draft 
updated  plan  integrated  the  crucial  need  to  enhance  flexibility  and  demand 
response,  and  mentions  the  importance  of  sector  coupling,  the  plan  remains 
general on this issue. 

Research, 
innovation 
and 
competitiv
eness 

The NECP presents in a general manner policies, support programmes on energy, 
as well as the funding sources linked to climate and energy.  

The  plan  does  not  provide  operational  details  on  the  planned  research  and 
innovation (R&I) actions in the energy sector, such as priorities and objectives for 
R&I  coupled  with  financial  allocations  or  funding  targets,  and  implementation 
milestones  that  could  demonstrate  quantitative  pathways  to  reaching  the  2030 
and 2050 objectives for energy.  

Just 
transition 

The  NECP  includes  some  measures  to  support  competitiveness  of  clean  energy 
technologies and the manufacturing, scaling up and diversification of commercially 
available  clean  energy  technologies,  equipment  and  components.  Nevertheless, 
the plan lacks information on concrete measures and investments to overcome the 
identified skills gaps. 

Just  transition  is  only  partially  addressed  in  the  draft  updated  NECP.  The  plan 
provides limited information on social, employment and skills impacts, including 
distributional impacts, of the climate and energy transition. It does not elaborate 
on  the  measures  addressing  access  and  preservation  of  employment  and 
education and training in the context of the transition, neither in the coal regions 
nor more broadly. 

However, the measures in the plan reflect the 2023 European Semester Country 
Specific Recommendations. 

needs, 

Investmen
t 
Policies 
and 
Measures 

The  plan  does  not  provide  an  estimate  of  the  investment  needs  and  funding 
sources. 

The methodologies behind s behind the with existing measures (‘WEM’) scenario 
are not explained. The with additional measures (‘WAM’) scenario is not included. 
The  impact  assessment  of  policies  and  measures  is  purely  qualitative. 
Furthermore, no macro-economic assessment was provided. 

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As  previously  mentioned,  evidence  shows  that  the  Governance  Regulation  has  not  been 
given  particular  attention  in  Germany.  In  January  2024,  in  an  open  letter,  eight 
environmental  and  development  organisations  called  on  Federal  Chancellor  Scholz  and 
other relevant ministries to achieve the EU's climate targets in a socially just manner and 
to  comply  with  EU  law  (including  the  obligations  stemming  from  the  Governance 
Regulation).777  Despite  good  progress  in  some  areas,  the  organisations  concluded  that 
Germany is lagging behind in several EU climate targets and EU level obligations. Several 
issues are mentioned in this open letter, including the need for additional efforts on energy 
efficiency,  the  lack  of  information  on  financing  measures,  insufficient  focus  on  energy 
poverty, and absence of adequate public consultation as required by the Aarhus Convention 
and the Governance Regulation. 

The German LTS submitted to the Commission in 2020 was prepared in 2016. However, in 
2019, the Federal Climate Change Act entered into force and was subsequently amended 
in July 2021. Hence, the European Commission’s assessment of Germany’s national LTS 
identifies  that  the  strategy  is  outdated  and  does  not  reflect  Germany’s  current  legal 
commitments  on  climate  and  energy.  Additionally,  the  national  LTS  includes  few  of  the 
mandatory contents. Several mandatory elements were missing, including: 

  Projected emission reductions and enhancement of removals by 2050; 
  GHG and CO2 intensity of GDP; 
  Emission trajectories by sector; 
  Estimated investment needs; 
  Strategies for research, development and innovation; 
  Socio-economic impact assessment. 

Most  of the non-mandatory contents  were also missing from the national LTS (e.g., the 
estimated  likely  share  of  renewable  energy,  the  estimated  likely  energy  consumption, 
adaptation  policies  and  measures,  main  drivers  for  energy  use  in  the  power  sector, 
transport  decarbonisation  options,  emission  reduction  options  in  the  agriculture  sector, 
links to agriculture and rural development policies).778 

According  to  two  consulted  stakeholders,  the  absence  of  a  mandatory  update  of  the 
national LTS and a binding template within the Governance Regulation constitute the main 
reasons behind the lack of crucial elements in the German - and other Member States’ – 
national LTS, coupled with a lack of regular updates. 779  

Article 18 reporting  

A major intention of introducing the Governance Regulation was to provide an integrated 
approach to planning and reporting on energy and climate policies, which was previously 
dispersed  across  several  regulations.  In  particular,  it  linked  the  national  planning  in  the 
NECPs to the reporting of policy impacts in the policies and measures (PaM) reports via the 
NECP progress reports.  

One  2023  study  found  that  the  objective  of  the  Governance  Regulation  to  establish  an 
integrated  framework  for  planning  and  reporting  of  national  energy  and  climate  policies 
has  not  yet  been  achieved  to  the  extent  desired. 780  Specifically,  it  found  that  the 

777 Germanwatch et al. (2024). Press release. Energy and climate plan: Germany threatens to miss EU targets in 
the transport and building sectors. Energy and climate plan: Germany threatens to miss EU targets in transport 
and buildings | Germanwatch e.V.  
778 Assessment of the Long-Term Strategies of EU Member States (europa.eu)  
779 Interview with think tank conducted on 22/01/2024; Interview with NGO conducted on 22/01/2024 
780 Wachsmuth, Jakob et al. 2023: National Energy and Climate Plans: Evidence of Policy Impacts and Options 
for more Transparency. A Meta Study assessing Evaluations of selected Policies reported in the Danish, French, 
German,  Slovenian,  and  Swedish  Plan.  Final  report.  Dessau-Roßlau:  German  Environment  Agency.  National 
Energy and Climate Plans: Evidence of Policy Impacts and Options for more Transparency | Ecologic Institute  

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harmonisation  between  the  different  planning  and  reporting  requirements  is  still 
insufficient and strongly limits the transparency of interlinkages. The objective of this study 
was  to  develop  an  in-depth  understanding  of  the  impact  of  the  policy  instruments  that 
selected Member States (including Germany) had included in their NECPs to reach their 
climate and energy targets.781 

Table 53 summarises the main problems and  related recommendations identified in this 
study,  which  were  confirmed  and  supported  by  one  interviewed  stakeholder  from  the 
German Environment Agency. It is interesting to notice that most of the critical elements 
identified  are  related  to  the  national  administrative  structure,  and  to  the  national 
implementation of the Governance Regulation.  

Table 53.  Summary of issues and recommendations identified in the Wachsmuth, Jakob 

et al. 2023 study 

Summary  of  problems 
identified  

Substantial  knowledge 
gaps  with  regard  to  PaM 
impacts.  

Summary of recommendations  

Improve the knowledge basis for transparent NECP updates 
as follow: 

Member States to conduct ex-post evaluations of at least the 
main PaMs on a regular basis tied to the policy cycle 

GHG impacts should be made an integral part of agricultural 
evaluations, if this has not happened already 

A  centralised  platform  would  be  a  key  step  to  increasing 
transparency  and  fostering  a  more  informed  selection  and 
evaluation of policies.782   

Insufficient 
transparency  about  the 
selection of policies and 
expected  impacts  in  the 
NECPs 
on 
interactions  with  other 
PaMS) 

(e.g., 

To improve the transparency of PaM selection and their role 
in the policy mix, the study suggests the following: 

The  role  of  NECPs  in  strategic  planning  of  the  policy  mix 
towards  2030  could  be  strengthened  if  they  contained 
information on single PaMs as well as the full policy mix, as 
this could be used to inform decisions about supplementing, 
replacing, or expanding existing PaMs.  

The  NECPs  would  particularly  benefit 
from  a  better 
description of the role of specific existing and planned PaMs 
in the mix and their  consistency,  coherence, credibility and 
comprehensiveness.  This  should  include  an  explanation  of 
which PaMs are key, and which are accompanying and why. 

The  NECPs  should  also  include  the  emission  reduction 
estimates for the key PaMs (whereby this information could 
also  come  from  the  PaM  reports  if  the  policies  in  the  PaM 
reports  are  in  line  with  those  in  the  NECP).  This  should 

781    Key  policy  instruments  from  five  selected  NECPs  were  examined  in  four  focus  topics:  carbon  and  energy 
pricing, renewable heating and cooling, energy-efficient buildings, and agricultural soils. The report shows the 
assessment of the expected impacts of these policy instruments and compared them with the findings of both 
ex-post and ex-ante evaluations. 
782 While the study acknowledges the progress made by the EEA catalogue and the PaM database in this regard, 
there  is  still  substantial  work  needed  to  provide  information  in  such  a way  that  the  link  between evaluations, 
policies, NECPs and PaM reports becomes transparent. 

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Summary  of  problems 
identified  

Summary of recommendations  

in 

Insufficient 
about 
transparency 
uncertainties 
the 
development and use of 
evaluations 
(i.e., 
evaluations were based on 
guidelines; 
different 
ex-post 
available 
evaluations  were 
not 
linked  to  the  preparation 
of  NECPs  and/or  PaM 
reports  bot 
to  other 
purposes) 

rules 

gaps 
of 

in 
Important 
reporting 
PaMs 
impacts  with  regard  to 
climate 
energy  and 
objectives  (there  are  no 
clear 
for 
harmonisation,  no  explicit 
requirement 
include 
PaM  impacts  from  PaM 
reports  on  NECPs  or 
no 
reports, 
progress 
obligation 
consider 
to 
conflicts  and  synergies  on 
the level of PaMs.  

to 

include ex-ante estimates that take into account the findings 
of ex-post evaluations.  

Harmonisation of the reporting requirements under the EED 
and  

the Governance Regulation is urgently required. To address 
uncertainties  in  a  more  transparent  way,  the  following 
suggestions are made: 

Both  ex-post  and  ex-ante  evaluations  meant  to  inform 
national  energy  and  climate  policies  should  follow  existing 
guidelines as much as possible; 

Integrate the requirement to measure the PaM contributions 
to  the  core  objectives  of  energy  and  climate  policy  into  all 
relevant policy evaluations and establish a consistent choice 
of baselines for such evaluations, for instance building on the 
with-existing-measures scenarios used in the NECPs. 

Improve  planning  on  the  national  level  by  using  the  same 
template for all ex-ante evaluations of PaMs. 

Potential improvements to the EU governance framework:  

enforce  a  higher  degree  of  harmonisation  between  NECPs, 
Progress Reports and PaM reports; 

harmonise  the  baselines  between  NECPs,  Progress  Reports 
and PaM reports building on the requirements of the NECPs, 
i.e. allowing for a comparison between current and planned 
policies; 

if  a  Member  State  keeps  the  PaM  report  separate  from  the 
NECP  progress  report,  the  progress  report  should  clearly 
reference  the  PaM  report  and  corresponding  evaluations  of 
PaMs; 

make reporting the contributions of PaMs to RES expansion 
mandatory if available. The same applies to contributions to 
energy efficiency 

Source:  ICF  elaboration;  Wachsmuth,  Jakob  et  al.  2023:  National  Energy  and  Climate 
Plans:  Evidence  of  Policy  Impacts  and  Options  for  more  Transparency.  A  Meta  Study 
assessing  Evaluations  of  selected  Policies  reported  in  the  Danish,  French,  German, 
Slovenian, and Swedish Plan. Final report.  

A5.4.6. Lessons learnt and recommendations  

This section describes the main lesson learnt and recommendations stemming from desk 
research and stakeholders’ consultation on the implementation of selected obligations from 
the Governance Regulation in Germany.  

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NECPs, NECPRs and public consultation 

Evidence collected for the purpose of this case study suggests that, in Germany, the NECP 
is a collection of existing policies and measures and does not drive national monitoring or 
planning processes on climate and energy policy.  

The same can be said for the obligation to carry out a public consultation: more ad hoc 
consultations already take place on single policies and measures within national legislative 
procedures. Hence, the public consultation on the NECP is not intended to gather feedback 
on  draft  measures,  as  these  consultations  follow  different,  more  ad  hoc  processes  and 
timelines.  

Consultations with national authorities reveal that the learning curve stemming from the 
entry  into  force  of  the  Governance  Regulation  and  related  reporting  obligations  is 
decreasing, with national authorities being more used to reporting templates, procedures, 
and timelines. Consequently, national authorities did not express the need for a substantial 
revision of the Governance Regulation, but rather additional support or targeted guidance, 
to  ensure the timely,  completeness and comparability of the  reported information (e.g., 
through dedicated workshops, or exchanges among Member States national authorities).     

Long-term Strategy 

The German LTS is outdated and did not include all the mandatory elements. Hence, the 
following recommendations could be put forward: 

  The update of the national LTS should be mandatory rather than voluntary; and  
  The template for the national LTS should also be mandatory.  

Table 54.  List of stakeholders  

A total of 18 stakeholders have been contacted. Among these, seven stakeholders have 
been interviewed, while the remaining ones either declined the invitation or did not reply.  

Table 55.  Stakeholders consulted for the case study in Germany 

Stakeholder type 

Interview date  

National 
(DE) 

National 
(DE) 

Authority 

17 January 2024 

Authority 

19 January 2024 

Academic 

19 January 2024 

Think tank  

22 January 2024 

NGO 

National 
(DE) 

National 
(DE) 

22 January 2024 

Authority 

15 February 2024  

Authority 

15 February 2024 

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Table 56.  Documents reviewed  

Document type 

Author(s) and title 

NLTs assessment 

Ricardo  Energy  &  Environment.  Assessment  of  the 
Long-Term  Strategy  of  Germany.  Summary  of  main 
findings. 

Year 

ND 

Draft NECP  

Federal  Ministry  for  Economic  Affairs  and  Energy. 
Draft  of  the  Integrated  National  Energy  and  Climate 
Plan.  

2018 

Staff 
Document 

Working 

European  Commission.  Staff  Working  Document. 
Assessment of the draft NECP 

2019 

Recommendation 

European Commission. Recommendation on the draft 
integrated  National  Energy  and  Climate  Plan  of 
Germany covering the period 2021-2030. 4405 final 

2019 

Staff 
Document 

Working 

European  Commission.  Assessment  of  the  final 
national energy and climate plan of Germany.  

2020 

Final NECP 

Implementing 
regulation 

Federal  Ministry  for  Economic  Affairs  and  Energy. 
Integrated National Energy and Climate Plan.  

ND 

Regulation 

Implementing 

Commission 
(EU) 
2022/2299  of  15  November  2022  laying  down  rules 
for  the  application  of  Regulation  (EU)  2018/1999  of 
the European Parliament and of the Council as regards 
the structure, format, technical details and process for 
the  integrated  national  energy  and  climate  progress 
reports 

2022 

Report 

LIFE PlanUP. Report on Good Practices in Energy and Climate 
Governance  

2019  

Staff 
Document 

NECP 

Study 

Report  

Press release  

Working 

European  Commission.  Assessment  of  the  draft  updated 
integrated national energy and climate plan of Germany.  

2023 

Draft  updated  integrated  national  energy  and  climate  plan  of 
Germany. 

2023 

Wachsmuth, Jakob et al. National Energy and Climate Plans: 
Evidence  of  Policy 
for  more 
Transparency. A Meta Study assessing Evaluations of selected 
Policies  reported  in  the  Danish,  French,  German,  Slovenian, 
and  Swedish  Plan.  Final  report.  Dessau-Roßlau:  German 
Environment Agency. 

Impacts  and  Options 

2023 

CAN Europe; WWF. Public participation in national energy and 
climate  plans.  Evidence  of  weak  and  uneven  compliance  in 
Member States  

2023 

Germanwatch.  Press  release.  Energy  and  climate  plan: 
Germany  threatens  to  miss  EU  targets  in  the  transport  and 
building sectors.  

2024 

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A5.5. Case study – Malta 

A5.5.1. Background  

The Governance Regulation falls primarily within the remit of Malta’s Directorate-General 
for Energy, and the Ministry for Energy and Water Management is the lead Ministry in the 
development of the NECP, though other ministries and bodies also provide some inputs. 
The  Ministry  for  Environment,  Climate  Change  and  Planning  collaborates  in  fulfilling  the 
obligations  of  the  Governance  Regulation  and  led  the  development  of  the  Malta’s  Long-
Term  Strategy  (LTS),  which  was  released  in  2021.  The  LTS  included  inputs  from  the 
Ministry  for  Energy  and  Sustainable  Development  and  the  Ministry  for  Transport, 
Infrastructure and Capital Projects. The LTS was developed to reach carbon neutrality by 
2050 and recovery from the COVID-19 pandemic.  Malta Resources Authority, an authority 
of the Ministry for Environment, Climate Change and Planning , supports climate reporting 
under the Governance Regulation.783 

Malta’s  LTS784  includes  policies  and  measures  (PaMs)  to  achieve  the  expected  GHG 
emission  reduction  target  by  2050  and  includes  projections.  However,  the  LTS  excludes 
some  mandatory  contents  of  member  states’  long  term  strategies,  such  as  the  national 
LULUCF’s emission reduction and removals and the CO2 intensity of GDP.  

Matla’s final NECP was submitted on time, and mostly contained complete information. 785 
A couple of remaining gaps are information on energy subsidies and actions being taken in 
this regard (it is known that such subsidies exist), as well as goals related to adaptation. 
During  an  interview,  a  third-sector  stakeholder  expressed  concern  about  the  regressive 
nature of the current practice of uniformly subsidizing energy prices. This policy, sustained 
over  recent  years,  utilizes  public  taxes  to  subsidize  energy  consumption  for  all  citizens. 
However, it disproportionately benefits higher-income individuals who typically  consume 
more  energy.  The  stakeholder  explained  that  better  information  on  energy  subsidies  is 
important to begin to address such concerns. 

An  online  public  consultation  on  the  NECP  was  held  before  the  publication  of  the  NECP. 
Written  feedback  was  submitted  by  13  organisations  and/or  public  citizens.  A  public 
consultation  event  was  also  held  to  receive  direct  feedback.  The  outcomes  of  these 
consultations are presented in Malta’s final NECP in 2019. A strategic environmental impact 
assessment  was also  carried  out but  was not  completed in time for the  outcomes to be 
integrated into the plan.166 

The Commission recommended increased ambition in several areas, including: 

  Decarbonisation – GHG emissions and removals 
  Decarbonisation – Renewable Energy  
  Energy Efficiency 

In terms of GHG emissions, Malta plans to meet its 2030 targets by purchasing emissions 
allocations  from  other  Member  States,  and  in  terms  of  renewable  energy  and  energy 
efficiency,  national  targets  are  not  sufficient  contributions  to  the  Union’s  2030  targets 
based on projections and trajectory.786 

Malta is already above  the 15% EU target for  electricity interconnectivity and  estimates 
that it will maintain a level of 24% for 2030, through power grid interconnector with Sicily. 

783 Interview with national authorities 
784 See: https://unfccc.int/sites/default/files/resource/MLT_LTS_Nov2021.pdf 
785  Commission  NECP  Assessment  -  https://commission.europa.eu/publications/commission-recommendation-
assessment-swd-and-factsheet-draft-updated-national-energy-and-climate-0_en 
786  Malta  draft  updated  NECP  -  https://commission.europa.eu/document/download/f30c8368-abf8-4272-9a97-
93e41e221fcb_en?filename=MALTA_DRAFT%20UPDATED%20NECP%202021%202030.pdf 

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Malta is also signatory to the Clean Energy for EU Islands initiative, although this is not 
reflected in the final plan.  

Figure  57  provides  an  overview  of  the  key  climate  and  energy  objectives,  targets  and 
contributions,  as  outlined  in  the  2023  draft  updated  NECP  of  Malta.  Third  sector 
stakeholders  spoken  to  in  this  study  commented  that  the  projected  Renewable  Energy 
share remains very low compared to the 2030 target. 

Figure 59. Malta’s key objectives, targets and contributions 

Source:  European  Commission  (2023)  Factsheet:  Malta’s  draft  updated  National  Energy 
and Climate Plan 787 

A5.5.2. Main costs and benefits of the Governance Regulation  

Main costs  

Administrative burden and estimate of time spent: 

For Malta, the reporting burden of the Governance Regulation is particularly poignant as 
the country has a relatively small administration team, and it is not easy to scale-up the 
team  to  cope  with  additional  burden.  The  Governance  Regulation  contains  23  reporting 
streams and two different reporting systems, and there is a need to collate all the data 
from the relevant organisations which input, bring it all into one place, before separating 
it again to input the data into the 23 reporting streams in a different system. The Reportnet 
platform is deemed useful for the most part, but the issue remains with having to have the 
data in two different formats for two different purposes.788 

There is a perception among national authorities that an increased amount of reporting is 
necessary,  given  the  recent  proliferation  of  relevant  legislation  and  agreements,  and 
therefore administrative burden is increasing in general. There is acknowledgement that 
this  burden  has  not  increased  proportionately  in  line  with  the  number  of  additional 
requirements, due to  efforts  on the part of the European  Commission, however there is 
still  room  for  improvement  to  minimise  administrative  burden.  According  to  a  national 

787 Available here: Factsheet_Commissions_assessment_NECP_Malta_2023.pdf (europa.eu)  
788 Interview with national authorities. 

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authority  from  Malta  that  participated  in  the  targeted  survey,  costs  associated  with 
preparing and submitting reports have increased, including as a result of:  

  preparation and cross-service coordination for national plans and reports,  
  running costs for coordination and data compilation,  
  adopting a template for planning and reporting obligations,  
 

introducing  protocols  and  processes  to  comply  with  planning  and  reporting 
obligations,  

  entering data on EU electronic reporting platforms,  
  organising multilevel dialogue and stakeholder consultation on draft NECP,  
  human resources to fulfil obligations.  

Costs  for  external  consulting  and  support  remain  the  same  as  before  the  Governance 
Regulation.  

Estimating  costs  is  complicated  by  the  fact  some  activities  performed  to  support 
Governance Regulation reporting are not necessarily entirely or even primarily performed 
for  that  purpose.  Information  is  not  kept  on  amounts  of  time  spent  on  these  duties. 
Nevertheless, it is known that the Energy and Water Agency, which compiles energy data, 
employs  nine  people,  the  Climate  Change  Unit  at  the  Malta  Resources  Authority,  which 
compiles climate data, also employs nine people, and the Ministry for Environment, Energy 
and Enterprise has two people who coordinate the work.171 Assuming each of these people 
spends half their time on tasks associated with reporting under the Governance Regulation, 
this equates to 10 FTE personnel. Others will contribute from line ministries in the provision 
of data, but this data will in general be collected anyway and the research team was not 
made  aware  during  the  consultation  of  any  data  being  collected  specifically  for  this 
purpose. Stakeholders did not mention any additional costs or seeking of external support 
in  the  interviews  with  national  authorities  or  during  the  targeted  survey  of  national 
authorities. 

Consideration of improvements: 

One point stressed by national authorities during interview is that streamlining should not 
mean  simply  aligning  dates  but  also  having  them  in  a  logical  order.  Currently,  GHG 
inventory  data,  projections,  and  NECP  update  reporting  all  have  a  deadline  in  March. 
Logically speaking, projections need to follow from the energy data, and the policy planning 
inherent in NECP update reporting needs to follow from both of those. National authorities 
therefore called for the timelines to allow sufficient time (e.g. some months) for the latest 
reports to feed into the NECP update reporting, for example. 

The  second  point  to  consider  is  the  crossover  between  reporting  under  the  Governance 
Regulation and reporting to the UNFCCC. In addition to ensuring that reporting dates are 
aligned, as explained above, there is also a need to reduce the duplication of reporting. 
One  approach  could  involve  using  submissions  for  multiple  reporting  purposes,  where 
feasible. Alternatively, where this is not possible, ensuring that formatting aligns and is as 
similar  as  possible  can  facilitate  the  transposition  of  reporting  data,  thus  reducing 
duplicative  efforts.  This  would  also  be  the  case  between  the  Governance  Regulation 
reporting and reporting to EUROSTAT, for example, where there can often be complications 
with  differences  in  figures  reported  for  the  same  metrics  due  to  having  to  report  them 
twice in quick succession using slightly different templates. National authorities explained 
that the international community has been adding layers of reporting for a while and called 
for the process to be rationalised to minimise duplicated effort. 789  

789 Interview with national authorities. 

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The focus should come back to policy planning, but the focus on the five dimensions of the 
Energy  Union  does  not  create  the  best  structure  for  a  public  policy  planning  document, 
according to national authorities. This format leads to significant repetition, undermining 
readability  and  logistical  efficiency.  The  emphasis  on  consolidating  various  information 
sources  on  financial  flows  and  tangible  impacts  to  fulfil  reporting  obligations  can 
overshadow the document's primary purpose, namely public consultation. There is a feeling 
that  all  this  information  is  not  strictly  necessary  for  policy  planning,  which  is  the  stated 
purpose, and can distract from this use in a context where the same people have to split 
their time between reporting and policy planning. 

Main benefits  

Feedback from a national authority in Malta received during the survey points to benefits 
in the following areas: 

  Improved quality and timeliness of information produced 
  Better coherence of planning and reporting timelines and procedures 
  Better coordination of different competent authorities/Ministries 
  Better established processes, policies and procedures 
  Improved quality and accuracy of Malta’s planning and reporting 
  Streamlined and simplified reporting process in Malta 
  Better integration of different but related planning and reporting obligations 
  Different  cooperation  of  services  to  comply  with  Malta’s  integrated  planning 

obligations.  

However, the respondent was unable to identify any savings in time and/or resources for 
planning and reporting (for example, because of rationalisation, use of common templates 
and IT tools). No quantitative information was available on amounts of time or resources 
saved. 

One third sector stakeholder that was interviewed noticed that there has been a definite 
increase  in  the  level  of  consultation  required  in  policy  planning,  and  that  consequently 
there  is  more  information  and  visibility  of  public  policy  processes.  The  stakeholder  did 
however say that while more opportunities for meaningful consultation are ingrained in the 
process, these opportunities are often not adequately taken, due to decisions taken at the 
national/ministerial level. . It has been useful in any case to be able to see that Malta’s 
Renewable  Energy  and  Energy  Efficiency  plans  are  not  aligned  to  EU  targets  and  that 
further ambition is needed, as noted by the European Commission in its assessment  on 
the NECP. 

Another third  sector  stakeholder commented during an interview that  the data provided 
was useful in compiling a report on their recommendations and overview of energy system, 
and reasonably well accessible. However, they questioned the perceived need for them to 
publish  such  a  report  in  the  first  place,  given  that  they  felt  the  information  was  not 
published in a transparent enough way to engage the publish in the first place. 

A5.5.3. Public consultation and multilevel climate and energy dialogues 

Public consultation on the NECP  

Six different consultations were held on the NECP790 – with academia and NGOs, industry 
and others in addition to the public consultation. Consultation also took place on individual 
policies and measures as well, so that most had been consulted on even before that point. 
There are fairly standardised processes for consultations at the government level and these 
were  followed791.  During  the  online  public  consultation  process,  13  organisations  and/or 

790 Interview with national authority 
791 https://www.gov.mt/en/publicconsultation/Pages/Policy-Making-Process.aspx 

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citizens provided feedback. The public consultation process began at the beginning of 2019 
after the finalisation of the draft NECP, the feedback is therefore included in the final NECP 
published in 2019792, complying with Article 10 of the Governance Regulation.  

A  separate  public  and  stakeholder  consultation  was  also  conducted  for  the  Strategic 
Environmental Assessment (SEA) and the Research & Innovation Strategy for Energy and 
Water.  In  the  2019  NECP,  it  states  that  a  declaration  of  adoption  and  a  summary  of 
monitoring measures will be released to the public to comply with the SEA regulation (S.L. 
549.61). However, as the timeframe for completion of SEA does not align with the NECP, 
the SEA is still in the scoping stage.  

The  public  expressed  several  opinions  and  concerns  during  the  consultation  on  Malta's 
NECP. There were perceived inadequacies in integrating the plan with previous strategies 
and insufficient NGO involvement. Questions arose regarding Malta's progress toward 2030 
emission reduction targets and intentions regarding the purchase of allowances. The public 
urged addressing climate change effects and applying the 'polluter-pays principle' to the 
services sector. Multiple inquiries focused on renewable energy, advocating for progressive 
targets  and  exploring  alternative  sources  like  wind  and  solar  photovoltaics.  Energy 
efficiency  feedback  emphasised  the  lack  of  incentives,  particularly  in  the  commercial 
sector. Building-related concerns included the  need  for  stronger consideration of  energy 
performance and incentives for renewables. Issues raised in the areas of internal energy 
market and security included perceived risks associated with the gas pipeline project and 
queries  about  future  gas  distribution  plans.  Numerous  comments  were  provided  on  the 
topic of transportation, emphasising alternative options, mass transit, and incentives for 
electric vehicles, while highlighting the need to promote modal shift and reduce reliance 
on cars. 

There was a feeling among the multiple third sector stakeholders interviewed that despite 
these consultations, stakeholders were not brought into the process early enough, and that 
they  were  used  primarily  to  rubber  stamp  things  that  had  already  been  decided  at 
ministerial  level.  Only  a  select  few  external  stakeholders  were  included  at  the  decision-
making stage, and these were chosen by the administration. One interviewed third sector 
stakeholder mentioned that they have been asking to be involved in the consultation on 
the updated NECP since April 2023, but they have been told that consultation on this will 
occur at a later date. A suggestion that followed was to mandate consultations at an earlier 
stage of the NECP development and review how feedback and suggestions are handled. An 
interviewee  from  an  NGO  gave  the  example  of  the  recently  prepared  Sustainable 
Development Framework and National Environment Strategy, where the stakeholder felt 
that  consultation  was  better  conducted  in  that  a  short  high-level  document  was  made 
available  first,  and  then  consultation  could  happen  on  the  details  while  it  was  still  in 
development. 

Consultation on the national LTS 

As for the national LTS, the consultation process comprised four stages conducted between 
August 2018 to August 2021. The first stage involved ‘key’ stakeholders who were involved 
in the phase of identification and quantification of the measures, and included Ministries, 
government entities, agencies and authorities. Meetings were set up to discuss a long list 
of mitigation measures relevant to each entity. In the second stage, a fresh consultation 
process  was  carried  out  to  collect  further  insights  from  other  stakeholders,  which  was 
followed  by  a  number  of  consultation  sessions  on  adaptation  measures.  The  long  list  of 
measures was reduced, and during January and February 2020, the Ministry undertook a 
third  stage  of  consultations  with  stakeholders,  allowing  for  further  feedback  and 
discussions to be included in the draft. The preliminary mitigation and adaptation measures 
were  presented  to  the  Climate  Action  Board,  and  separate  meetings  were  held  with 

792 Malta NECP (2019) - https://energy.ec.europa.eu/system/files/2020-01/mt_final_necp_main_en_0.pdf 

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representatives  of  the  regional  committees  and  local  councils,  a  selection  of  academics, 
business representatives from the Chamber of Commerce and from the Chamber of SMEs 
(transport section), as well as various members of civil society. Finally a draft document 
was shared with the public. 

A public consultation document ‘Towards a Smart Specialisation Strategy 2021-2027 for 
Malta’, highlighting the potential research, development and innovation areas, was sent to 
various entities and individuals as part of the public consultation process in June 2021. The 
consultation  closed  in  August  2021  and  the  feedback  was  analysed.  Following  this,  the 
national LTS was updated in the same year.  

Malta’s national LTS highlights the preliminary mitigation and adaptation measures already 
presented  in  May  2020,  a  year  before  the  Climate  Action  Board  and  the  shortlisted 
measures by stakeholder groups. Thus, stakeholders were provided sufficient time to have 
perspectives before the public consultation. The full contents of the feedback and how the 
LTS responded to the recommendations made during consultation stage is however missing 
from the final LTS published in October 2021. 

Multi-level climate and energy dialogue  

Multi-level  Energy  and  Climate  Dialogues  (MLCEDs)  must  be  implemented  by  Member 
States  under  Article  11  of  the  Governance  Regulation.  Based  on  the  preliminary 
assessment of the progress of implementation of MLCED 793,12 Member States submitted 
their MLCED reports before the cut-off date of 21 August 2023, among which was Malta.  

Although  Malta’s  MLCED  was  delayed,  it  met  most  of  the  requirements.  Malta  has 
established a new dialogue structure. In the case of MLCED formats, Malta reported five 
elements  including  a  working  group,  awareness  campaign,  online  platform,  national 
conference and targeted workshops. 794 

Malta  especially  highlighted  the  “ClimateOn”  awareness  campaign  that  stimulates 
dialogues  between  stakeholders,  supported  by  an  online  platform.  When  assessing  the 
nature of dialogues, the multilevel dimension is unclear based on Malta’s reporting. Malta’s 
MLCED  engaged  stakeholders  including  civil  society  organisations  and  businesses.  It  is 
concluded in the cited report that Malta’s stakeholder engagement is active in discussion 
of thematic areas and civil society fora. The third sector stakeholders interviewed however, 
were not aware of the MLCED having happened at all, signifying that maybe civil society 
consultation didn’t go far enough. 

In terms of thematic scope, for which the Governance Regulation requires Member States 
to include specific topics in the MLCED reports, Malta failed to include either the mandatory 
or non-mandatory scopes, including EU climate neutrality objectives, scenarios for energy 
and climate policies, progress review, and references to NECPs and LTS. The assessment 
analysed the reports from Member States and suggest that the upcoming revision of the 
Governance Regulation clarify Article 11 to make it more precise.  

A5.5.4. Regional cooperation 

Recognising the need for regional cooperation on energy and climate since 2014, Malta has 
actively  engaged  in  mechanisms  such  as  the  Declaration  on  Environment  and  Climate 
Change under the Union for the Mediterranean (UfM)795. Flexible compliance options, like 

MECD 

(2023) 

Assessment 

793 
https://www.ecologic.eu/sites/default/files/publication/2023/33007-Multilevel-Climate-Energy-Dialogue-
Reporting-Preliminary-Assessment.pdf 
794 
https://www.ecologic.eu/sites/default/files/publication/2023/33007-Multilevel-Climate-Energy-Dialogue-
Reporting-Preliminary-Assessment.pdf  
795 The UfM is an an intergovernmental organization of 43 member states from Europe and the Mediterranean 
Basin that aims to promote stability and integration throughout the Mediterranean region 

Assessment 

Institute 

Institute 

Ecologic 

Ecologic 

(2023) 

MECD 

- 

- 

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bilateral  agreements  with  other  Member  States,  are  pursued  with  the  intention  of 
contributing to emissions reductions beyond assigned national targets. Active participation 
in  the  Concerted  Action  of  the  Energy  Efficiency  Directive  (CA-EED)  targets  knowledge-
sharing in energy efficiency.796 

The Med9 initiative was included in the NECP, which was a first for Malta in terms of having 
regional cooperation specifically around climate and energy. As a part of the Med9 group 
(Italy, Croatia, Cyprus, France, Greece, Malta, Portugal, Slovenia, and Spain), Malta aims 
to create a regional green energy hub based on the draftNECP of 2023. In the future, Malta 
is seeking more regional cooperation focusing on RES (Renewable Energy Sources) projects 
considering the potential amount of tangible benefits. 

There are also specific projects, including the power grid interconnector with Sicily, also 
known as the MTGP (Melita TransGas Pipeline797), as a very important example in terms of 
impact  on  climate  and  energy.  A  second  natural  gas  interconnector  is  also  planned. 798 
During  an  interview,  a  stakeholder  from  the  third  sector  highlighted  the  significance  of 
regional collaboration concerning interconnectors for renewable energy. They emphasized 
the  need  to  prioritize  renewable  energy  interconnectors  over  natural  gas  alternatives, 
noting  that  while  the  latter  might  offer  short-term  emission  reductions,  they  would 
ultimately  require  phasing  out  to  align  with  long-term  sustainability  goals.  In  the 
assessment of Malta’s draft updated NECP, the European Commission recommended that 
Malta “pursue regional cooperation for the development of renewable energy projects; in 
particular  by  describing  how  Malta  plans  to  establish  a  framework  for  cooperation  with 
other  Member  States  by  2025,  in  line  with  Article  9  of  Directive  (UE)  2018/2001  as 
amended”.799 

Throughout the regional cooperation process, Malta has been identified as having limited 
technical capacity in cutting-edge renewable technology and facing challenges in sustaining 
a  demand  for  them.  The  mitigation  potential  of  Malta,  a  country  with  a  service-based 
economy, is also limited, which leads to high GHG emission mitigation cost compared to 
other  countries,  thus  posing  a  financial  obstacle.  Malta,  therefore,  must  consider  socio-
economic factors while planning and implementing the transition. Balancing environmental 
goals  with  economic  and  social  considerations  can  be  challenging.  Under  these 
circumstances, the engagement of bilateral agreements between Malta and other Member 
States  based  on  the  Effort  Sharing  Regulation  has  allowed  Malta  to  achieve  emission 
reductions exceeding the assigned national target by buying allocations from other Member 
States.  

During  the  development  of  the  NECP,  and  in  line  with  Article  12(2)  of  the  Governance 
Regulation, Malta has sought consultation with relevant neighbouring Member States. The 
main  country  Malta  focused  on  for  regional  cooperation  is  Italy.  In  September  2019,  a 
bilateral meeting was held between key representatives from Malta and Italy. Both Member 
States reached agreement to cooperate in technical skill-sharing to meet 2030 EU targets. 
Malta's unique geographical position, connecting to the European electricity grid through 
Italy,  underscores  the  importance  of  regional  cooperation,  especially  in  developing  the 
electricity market and advancing the gas pipeline project with Sicily. The implementation 
of MTGP is expected to produce a positive outcome both financially and environmentally 
based  on  environmental  impact  assessment,  although  the  long-term  sustainability  of 

796 Malta NECP (2019) - https://energy.ec.europa.eu/system/files/2020-01/mt_final_necp_main_en_0.pdf  
797 See: https://melitatransgas.com.mt/  
798 
See: 
environmental.1051541  
799 Malta Draft NECP Update Assessment (2023) - https://commission.europa.eu/document/download/cf47a01d-
e1db-4868-918d-edc0639b295e_en?filename=Recommendation_draft_updated_NECP_Malta_2023.pdf  

https://timesofmalta.com/articles/view/second-electricity-interconnector-gets-green-light-

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Malta’s  use  of  national  gas  was  questioned  during  the  LTS  consultation.800  The  MTGP 
project stimulates continuous cooperation with the Italian authorities.801 

The National Research and Innovation Strategic Plan highlights the growing significance of 
strategic  cooperation  at  both  bilateral  and  regional  levels,  emphasising  the  need  to 
establish  meaningful  partnerships  in  Research  and  Innovation  (R&I)  that  align  with  key 
European  initiatives.  Malta,  in  collaboration  with  Cyprus  and  the  Netherlands,  has  also 
launched the Mediterranean Island Cleantech Innovation Ecosystem (MICIE) project. This 
initiative aims to formulate action plans to strengthen R&I endeavours in Malta and Cyprus. 
Furthermore,  Malta  plays  an  active  role  in  the  Clean  Energy  Transition  Partnership, 
demonstrating  its  commitment  through  a  designated  national  contribution  of  EUR  3.5 
million.181  

Malta recognises the need for regional cooperation and has pursued it more widely than 
merely complying with the NECP, but their focus is on the Energy Security and Renewable 
Energy dimensions which have joint drafting with other Member States for the development 
of the NECP. Malta seeks to enhance energy security through diplomacy within and outside 
of the EU, in line with foreign policy guidance. This has been the policy of the government 
since before the introduction of the Governance Regulation and is pursued across all areas 
of policy irrespective of such legislation. Therefore, the Governance Regulation cannot be 
said to be a driving force of such policy in general.802 

A5.5.5. Compliance mechanisms  

The general process for preparing and delivering NECPs runs as follows:183  

  The Malta Resources Authority collates GHG data through contact with relevant line 

ministries.  

  The  Energy  and  Water  Agency  does  the  same  for  energy  data.  The  Ministry  for 
Environment,  Energy  and  Enterprise  handles  energy  security,  adaptation  and 
regional  cooperation,  and  also  has  a  role  in  data  provision  coordination,  and 
reporting around the NECP.  

  The Prime Minister’s office coordinates more widely with ministries. 

Measures are essentially taken nationally, although impacts can be felt in a locality.183 

Feedback received during the public review of the draft NECP in 2018, based on a public 
consultation,  highlighted  concerns  about  the  quality  of  the  draft  including  that  it  lacked 
sufficient measures, was not sufficiently ambitious for some targets, and lacked sufficient 
technical approaches. Malta has provided comments to address the feedback included in 
Annex I of the final 2019 NECP803 and added explanations as well as  revised measures. 
Nevertheless,  as  previously  stated,  during  the  consultation  multiple  third  sector 
stakeholders felt that they were only consulted too late in the process and only at a stage 
when it was possible to make minor modifications. 

In 2018, the European Commission provided a detailed assessment of the draft NECP, in 
line  with  the  Governance  Regulation.  Malta  received  ten  recommendations  and  included 
the recommendations within the final NECP in December 2019. The European Commission 
highlighted that the draft NECP focused largely on decarbonisation (GHG and renewable 
energy)  and  energy  efficiency  dimensions  and  lacked  clear  objectives  for  the  other 
dimensions. The European Commission also highlighted that neither the targeted scenario 
of renewable energy, nor energy consumption goals, are sufficiently ambitious. 

800  Malta  LTS  consultation  -  https://birdlifemalta.org/wp-content/uploads/2021/09/Low-Carbon-Strategy-
Consultation-Feedback.pdf  
801 Malta NECP (2019) - https://energy.ec.europa.eu/system/files/2020-01/mt_final_necp_main_en_0.pdf  
802 Interview with national authorities 
803 Malta NECP (2019) - https://energy.ec.europa.eu/system/files/2020-01/mt_final_necp_main_en_0.pdf  

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The final NECP report is still mainly focused on the previously highlighted dimensions but 
has improved on other dimensions such as internal energy market. Malta pointed out that 
there  were  difficulties  due  to  national  circumstances  to  address  and  follow-up  the 
comments.  The  main  obstacles  include  the  electricity  system  structure  of  Malta,  which 
makes  it  difficult  to  develop  a  renewable  energy  community,  the  sharp  increase  in  GDP 
and population (which poses a challenge to reducing energy consumption), and the lack of 
local  energy  resources  due  to  Malta’s  geographic  isolation,  which  makes  it  difficult  to 
enhance  energy  security.  In  general,  the  feedback  from  the  European  Commission  was 
addressed in the final 2019 NECP, or a justification was provided.  

For the national LTS for Malta, the LTS is led by the Ministry for the Environment, Climate 
Change,  and  Planning  (MECP),  with  input  from  the  Ministry  for  Energy  and  Sustainable 
Development,  and  the  Ministry  for  Transport,  Infrastructure  and  Capital  Projects.  The 
national  LTS  is  developed  through  collaboration  between  Malta’s  government  and 
individuals, households, civil society, and the private sectors. The LTS was initiated in 2018 
and finalised in 2021. The process included researching and selecting mitigation measures, 
quantifying abatement levels through Marginal Abatement Cost Curve (MACC) modelling 
and engaging with stakeholders. The  results from MACC modelling are  expected to help 
the government to anticipate the economic and societal costs and benefits associated with 
GHG  emissions  reductions.  During  the  process  of  developing  the  LTS,  the  COVID-19 
pandemic posed challenges and unavoidably impacted the assumptions and output. The 
LTS follows a four-year policy cycle that allows for periodic updates with the inclusion of 
new  data,  particularly  in  rapidly  evolving  areas,  and  adaptation  to  emerging  situations, 
even in a post-pandemic scenario. 804 

After  the  submission  of  the  LTS  in  2021,  the  strategy  was  reviewed  by  the  consultancy 
Ricardo in the support of DG CLIMA805. The review suggests that the overall completeness 
of the LTS is good and that it contains most of the mandatory contents and some of the 
non-mandatory contents, such as adaptation PaMs. Gaps in Malta’s LTS compared to the 
mandatory  requirements  are  the  CO2  intensity  of  GDP  and  emission  reductions  and 
removals in  LULUCF. Information  on  GHG emissions by  sources from  Malta’s agriculture 
sectors was also very limited in the LTS.  

Feedback  to  the  public  consultation  on  the  draft  LTS  (version  dated  June  2016)  from 
Friends of the Earth Malta, Moviment Graffitti and BirdLife Malta 806 also highlighted a need 
for more holistic effort on the Agriculture and LULUCF sectors. In response to the above 
points, the LTS emphasised that low land availability limits Malta’s ability to reduce GHG 
emissions in LULUCF and woodlands that act as natural carbon sinks. The LTS also lacks 
clear  objectives  for  2050  and  details  for  energy  sectors  including  energy  consumption 
estimations, energy emission trajectory, and renewable energy share after 2030. This is 
similar  to  the  assessment  for  Malta’s  NECP  –  the  goals  for  the  energy  sector  are  not 
sufficiently ambitious. The assessments and consultations for the NECP and LTS all pointed 
out  that  offshoring  and/or  exporting  GHG  emissions  to  other  Member  States  is  not  a 
sustainable  method  nor  a  solution,  and  a  high  percentage  of  renewable  energy  use  is 
crucial for Malta. One of the biggest barriers for renewable energy industry development 
within the country is the limited space for onshore renewable energy. 

One other comment made by a third sector stakeholder who was interviewed was that it 
was difficult to tell from the reporting how much of the compliance with a given target was, 
or will be, achieved through the purchase of allowances. This makes it harder to challenge 
the sustainability of this method. In addition, targets for which progress is only reported 

804 Malta LTS (2021) - https://unfccc.int/sites/default/files/resource/MLT_LTS_Nov2021.pdf 
805 Malta LTS Summary tables (2021) - https://ec.europa.eu/clima/sites/lts/lts_mt_summary_en.pdf 
806  Malta  LTS  consultation  -  https://birdlifemalta.org/wp-content/uploads/2021/09/Low-Carbon-Strategy-
Consultation-Feedback.pdf 

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every  five  years  are  more  difficult  to  track  in  the  absence  of  a  repository  of  up-to-date 
information. 

A5.5.6. Lessons learnt and recommendations  

The  first  recommendation,  from  an  administrative  side,  is  that  streamlining  should  not 
mean  simply  aligning  dates  but  rather  having  them  in  a  logical  order.  Currently,  the 
deadlines for GHG inventory data, projections, and NECP update reporting all fall in March. 
However, logically, projections need to follow from the energy data, and the policy planning 
inherent in NECP update reporting needs to follow from both of those. Therefore, timelines 
should allow some months for the most up-to-date reporting to feed in to the NECP update 
reporting for example. 

The  second  point  to  consider  is  the  crossover  between  reporting  under  the  Governance 
Regulation, and reporting to the UNFCCC. Apart from trying to  align reporting dates, as 
mentioned  above,  there  is  also  a  need  to  minimise  duplication  in  reporting  efforts.  This 
could involve consolidating submissions for multiple reporting purposes, or where this is 
unfeasible,  ensuring  that  formatting  is  similar/aligned  to  enable  the  transposition  of 
information and reporting. This also applies to reporting under the Governance Regulation 
reporting and to EUROSTAT, for example, where complications often arise with differences 
in  figures  reported  for  the  same  metrics  due  to  having  to  report  them  twice  in  quick 
succession in slightly differing templates.  

Another point to consider is the need to mandate consultations at an earlier stage, possibly 
just  after  an  initial  high-level  planning  document  is  published.  There  is  also  a  need  to 
review how suggestions received during consultation are handled.  

Several additional suggestions have been made and cited in this report, in terms of how 
Malta should act to meet its energy and climate targets. These include the recommendation 
that reliance on the purchasing of allowances to meet emissions targets is reduced, and 
progress on this more closely reported and tracked. Additionally, there is a suggestion to 
further limit dependence on natural gas interconnectors for meeting targets, recognising 
the need for a transition towards renewable energy solutions enabling Malta to meet its 
2030 targets.  

Table 57.  List of stakeholders consulted 

Stakeholder type 

Position/Role 

Interview date  

National authority 

Director  General  at  the  Ministry  of 
Environment, 
and 
Enterprise 

Energy 

14/12/2023 

National authority 

Coordinator  of  NECP  at  the  Prime 
Minister’s Office 

14/12/2023 

National authority 

Head of Climate Change Unit at the 
Malta Resources Authority 

14/12/2023 

National authority 

Head of Energy Unit at the Energy 
and Water Agency 

14/12/2023 

Third sector 

Director at  Malta Energy Efficiency 
and 
Energies 
Association 

Renewable 

19/12/2023 

Third sector 

Coordinator at Friends of the Earth 
Malta 

07/02/2024 

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Stakeholder type 

Position/Role 

Interview date  

Industry 

Funding  Secretary  at  Chamber  of 
Engineers 

16/02/2024 

Table 58.  Documents reviewed  

Document type 

Author(s) and title 

NECP Assessment 

Commission  Recommendation,  Assessment  (SWD) 
and  Factsheet  of  the  draft  updated  National  Energy 
and Climate Plan of Malta 

Year 

2023 

NECP 

MALTA Draft National Energy and Climate Plan 2021-
2030 

2023 

MLCED Assessment 

Progress on the implementation of national Multilevel 
Climate  and  Energy  Dialogues:  Assessing  Member 
States’ own reporting 

2023 

LTS 

Ministry 
for  Environment,  Climate  Change  and 
Planning - Malta’s Low Carbon Development Strategy 

2021 

LTS Assessment  

Malta  Low  Carbon  Development  Strategy  Friends  of 
the Earth Malta, Moviment Graffitti and BirdLife Malta 
Recommendations 

2021 

NECP Assessment 

Commission  Recommendation,  Assessment  (SWD) 
and  Factsheet  of  the  draft  updated  National  Energy 
and Climate Plan of Malta 

2020 

NECP 

NECP 

Ministry for Energy and Water Management - Malta’s 
2030 National Energy and Climate Plan 

2019 

Ministry for Energy and Water Management - Malta’s 
2030 National Energy and Climate Plan Draft 2018 

2018 

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A5.6. Case Study – Poland  

A5.6.1. Background  

Various  institutional  authorities  and  other  stakeholders  are  responsible  for  drafting  and 
implementing the NECP in Poland. 

The  development  of  the  Polish  NECP  involved  an  inter-ministerial  approach  and 
collaboration  between  various  government  agencies.  More  specifically,  the  NECP  was 
developed  by  an  inter-ministerial  working  team  coordinated  by  the  Ministry  of  State 
Assets.807  The  working  team  included  representatives  from  various  ministries,  including 
the  Ministry  of  Climate,  Ministry  of  Finance,  Ministry  of  Development,  Ministry  of 
Development Funds and Regional Policy, Ministry of Foreign Affairs, Ministry of Agriculture 
and  Rural  Development,  Ministry  of  Science  and  Higher  Education,  Ministry  of 
Infrastructure, Ministry of the Maritime Economy and Inland Waterways, Ministry of Family, 
Labour  and  Social  Policy,  and  the  Government  Plenipotentiary  for  Strategic  Energy 
Infrastructure.  Key  agencies  and  offices,  such  as  the  Energy  Regulatory  Office  (URE), 
Central  Statistical  Office  (GUS),  and  the  National  Centre  for  Emissions  Management 
(KOBiZE), were also part of the working team developing the Polish NECP. 

Responsibility for implementing measures outlined in Polish NECP rests on a range of public 
bodies and private entities. Entities involved in implementation include central and local 
government  bodies,  government  institutions,  fuel  and  energy  sector  entities,  economic 
operators, and research institutes. Various ministries also play a role in implementation, 
including  the  Ministers  competent 
for  energy,  environment,  transport,  regional 
development, agriculture and rural development, development, land use planning, spatial 
development  and  housing,  maritime  economy  and  inland  navigation,  economy,  foreign 
affairs,  public  finance,  family,  labour,  and  social  security,  science  and  higher  education, 
and  education  and  upbringing.  Government  Plenipotentiaries  for  Strategic  Energy 
Infrastructure and the "Clean Air" Programme are also involved. Regulatory bodies, such 
as the Polish Energy Regulatory Office (URE) and the National Atomic Energy Agency, also 
have roles in implementation, as does the National Fund for Environmental Protection and 
Water Management. Other organisations involved in implementation include transmission 
system operators, distribution system operators, and the storage system operator. 

The draft  NECP for Poland integrates the dimensions  of the Energy Union and considers 
recommendations from the European Commission, domestic development strategies, and 
public  consultations.  The  administrative  structure  involves  a  collaboration  of  ministries, 
government  agencies,  and  private  entities,  reflecting  a  coordinated  and  multi-sectoral 
approach to energy and climate policies in Poland.  

Polish NECP including key objectives, targets and contributions  

Poland submitted its draft integrated NECP to the European Commission on 9 January 
2019808,  shortly  after  the  deadline  set  in  Article  9  of  the  Governance  Regulation  (31 
December 2018). In June 2019, the European Commission published an assessment and 
country-specific recommendations to all Member States on their draft NECPs.809  

807 The Ministry of Energy changed its name to the Ministry of State Assets with effect from 15 November 2019. 
It  oversees  the  energy  and  mineral  deposits  management  departments  of  government  administration  as  of 
December 2019. 

808  Ministry  of  Energy  (January  2019)  Draft  of  the  Integrated  National  Energy  and  Climate  Plan  for  the  years 
2021-2030. 
https://energy.ec.europa.eu/system/files/2019-
here: 
03/ec_courtesy_translation_pl_necp_part_1_0.pdf  
809 European Commission (June 2019) Staff Working Document. Assessment of the draft NECP. Available here: 
https://energy.ec.europa.eu/system/files/2019-06/pl_swd_en_0.pdf  

Available 

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Taking these recommendations into account, Member States were required to submit their 
final NECPs by 31 December 2019. Poland notified the European Commission of its final 
NECP810 on 30 December 2019, thus meeting the deadline. In October 2020, the European 
Commission published the assessment and country-specific recommendation to Poland on 
its final NECP. 811 

Focusing on the five dimensions of the Energy Union, the table below summarises Poland’s 
key  climate  and  energy  targets  until  2030,  as  set  out  in  its  final  NECP812  including  the 
European Commission’s assessment across the various dimensions. 

Figure 60. Targets/objectives and measures in the final NECP 

Source:  European  Commission  (October  2020)  Staff  Working  Document.  Assessment  of  the  final 
national energy and climate plan of Poland 

By 30 June 2023, Member States were due to submit their draft updated NECPs in line 
with  article  14  of  the  Governance  Regulation813.  On  5  March  2024,  the  European 

of 

plan 

810  Ministry  of  National  Assets  (December  2019  Integrated  National  Energy  and  Climate  Plan  for  2021-2030. 
Available here: https://energy.ec.europa.eu/system/files/2020-08/pl_final_necp_part_1_3_en_0.pdf   
811 European Commission (October 2020) Staff Working Document. Assessment of the final national energy and 
climate 
https://energy.ec.europa.eu/system/files/2021-
here: 
01/staff_working_document_assessment_necp_poland_en_0.pdf  
812 European Commission (October 2020) Staff Working Document. Assessment of the final national energy and 
climate 
https://energy.ec.europa.eu/system/files/2021-
here: 
01/staff_working_document_assessment_necp_poland_en_0.pdf  
813  European  Commission  (October  2023)  State  of  the  Energy  Union  2023  Poland.  Available  here: 
https://energy.ec.europa.eu/system/files/2023-10/PL_SoEUr%20Fiche%202023.pdf  

Available 

Available 

Poland. 

Poland. 

plan 

of 

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Commission  published  the  draft  updated  NECP814,  which  Poland  submitted  after  the 
specified deadline. This document serves as a revision of the 2019 NECP for 2021-2030. 
The preparation of this document is in direct accordance with Article 14 of Regulation (EU) 
2018/1999, and Article 15ab of the Energy Law Act specifies that the minister overseeing 
energy,  in  collaboration  with  the  minister  overseeing  climate  matters,  is  tasked  with 
developing the NECPs, updates, and reports. Currently, these responsibilities are fulfilled 
by the Minister for Climate and Environment.  

The Governance Regulation also required Member States to submit their first national LTS 
to the Commission by 1 January 2020. Poland has not yet submitted its national LTS815. 

A5.6.2. Main costs and benefits of the Governance Regulation  

Main Costs 

During  an  interview,  one  national  authority  involved  in  reporting  on  climate  change 
adaptation explained that it had assigned four to five team members to this task in order 
to implement the reporting on this aspect and comply with the Governance Regulation 816. 

Interviewed stakeholders provided insights into the time commitment required to comply 
with  the  Governance  Regulation  requirements  and  indicated  that  the  process  may  have 
taken  varying  durations  for  different  team  members  before  the  reporting  deadline.  An 
interesting revelation was the absence of a dedicated information system for data import. 
Instead, staff employed a manual process, hinting at the resource-intensive nature of the 
reporting task. 

External  costs  may  have  arisen  due  to  cooperation  with  the  Institute  of  Environmental 
Protection.  In  2021,  four  to  five  people  may  have  been  engaged  in  such  collaborative 
efforts (the effort required in subsequent years remains unclear). 

Internal and external costs: organisational setup for preparing the NECP 

The  collaborative  efforts  needed  to  prepare  Poland's  NECP  entailed  both  internal  and 
external  costs  for  the  various  national  authorities  involved.  Such  collaborative  efforts 
included collectively identifying and gathering assumptions, and strategic analysis. A national 
authority assessed 817 that this collaboration spanned 24 units, with each of them engaging 
one  to  five  individuals  in  the  process,  depending  on  the  need.  Thus,  around  100  staff 
members from the Ministry of Climate and Environment departments and other institutions 
are estimated to have been involved. External costs have also arisen through collaboration 
with  an  external  contractor,  though  no  further  information  was  made  available  on  the 
extent of these costs. 

Overview of current processes for Governance Regulation compliance 

This  section  delves  into  a  multifaceted  discussion  that  emerged  during  two  case  study 
interviews818 with representatives from a national authority, unveiling the challenges and 

814 Ministry of Climate and Environment. National Plan in the field of Energy and Climate by 2030 (2019 update 
of  NECPs).  Preliminary  version.  Available  here:  https://commission.europa.eu/document/download/5118b15e-
d380-49ae-b8bb-41cc81a28e15_en?filename=PL_NECPupdate_Projekt_EN.pdf 

of 

plan 

Poland. 

815 European Commission (October 2020) Staff Working Document. Assessment of the final national energy and 
climate 
https://energy.ec.europa.eu/system/files/2021-
here: 
01/staff_working_document_assessment_necp_poland_en_0.pdf  
816 This case study presents the feedback received from a department of a national authority in Poland during the 
interview on 18 January 2024. As part of the Governance Regulation implementation, the authority’s responsibility 
involved reporting on adaptation to climate change, as outlined in Article 19, paragraph 1, which came into effect 
in 2021. The department has already reported for the second time on Poland’s national plans and strategies.  

Available 

817 Case study interview with a national authority in Poland on 4 March 2024. 

818 Case study interviews with a national authority in Poland on 18 January and 4 March 2024. 

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intricacies associated with the  reporting process. It highlights thoughtful considerations, 
queries, and reflections, initially focusing on the dynamic landscape of climate adaptation 
within  the  context  of  regulatory  frameworks  and  national  planning  processes,  and 
subsequently on the NECP preparation process. 

When outlining the process for the annual reporting cycle on adaptation to climate 
change, representatives from a national authority819 clarified that the emphasis is mainly 
on descriptive data, distinguishing it from the preparation of numerical and tabular data 
associated with national energy and climate plans, potentially falling under Article 17. The 
information  is  sourced  from  existing  data,  primarily  obtained  from  the  Institute  of 
Environmental Protection, operating under the supervision of the Ministry of Climate and 
Environment. Noteworthy is the Institute's supportive role for those engaged in reporting 
during 2021. 

 The  absence  of  an  updated  strategy  on  climate  change  adaptation,  and  in 
particular  a  lack  of  recent  risk  analysis,  posed  a  challenge  requiring  some 
information  from  the  2013  strategy  to  be  reused.820  Given  the  challenge  of 
conducting  new  research  every  two  years,  the  process  was  somewhat  streamlined  by 
reusing previously provided information. The process starts in January, with a specific focus 
on  gathering  new  information,  particularly  related  to  effective  financing  practices. 
Recognising the necessity for process improvement in reporting on adaptation to climate 
change,  there  is  an  emphasis  on  relying  on  information  from  regions  and  local 
governments.  Anticipating  a  new  strategy,  a  coordination  mechanism  is  set  to  be 
integrated to ensure the participation of all entities engaged in climate change adaptation 
reporting on an annual basis. This coordinated effort is intended to facilitate comprehensive 
reporting to the European Commission. 

The  climate  change  adaptation  reporting  process  is  centralised  and  predominantly 
occurs at the national level, involving collaboration between the Ministry  of  Climate and 
Environment  ministry  and  the  Institute  of  Environmental  Protection.  The  Institute's  role 
extends  beyond  mere  oversight,  encompassing  detailed  monitoring  and  assistance  in 
collecting  and  assembling  the  available  information.  The  Institute  takes  a  proactive 
approach  by  disseminating  relevant  data  and  insights  making  it  convenient  for  users  to 
access such information in its reports and website without requiring special requests. 

The Institute of Environmental Protection runs a website or portal, where climate scenarios, 
risk  assessments,  and  analyses  of  legal  acts  related  to  adaptation  are  accessible.  The 
platform also hosts a database showcasing good practices, along with educational materials 
like  lessons  for  teachers  and  videos.  Notably,  ongoing  efforts  are  mentioned  for  the 
continued development of this portal to enhance its functionalities in the future. 

These developments are the outcomes of a second project financed by the EU funds rather 
than  any  integral  parts  of  a  specific  strategy,  such  as  the  national  strategy  and 
programmes. A representative from a national authority821 believes that the Governance 
Regulation is posited to serve as a catalyst or impetus for instilling regularity and 
structure into this evolving process. 

During  the  interviews,  it  was  highlighted  that  there  is  a  need  to  simplify  the  reporting 
process  and  introduce  more  structured  information  in  subsequent  reporting  cycles.  The 
importance of incorporating climate change adaptation reporting into the strategy was also 
emphasised to mitigate the challenges posed by the lack of such information.822 

819 Case study interview with a national authority in Poland on 18 January 2024. 
820 Case study interview with a national authority in Poland on 18 January 2024. 
821 Case study interview with a national authority in Poland on 18 January 2024. 
822 Case study interview with a national authority in Poland on 18 January 2024. 

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Moreover, the necessity of involving regional and local authorities was underscored, as was 
the  need  to  urge  other  sectors  to  be  accountable  for  reporting  on  their  actions,  good 
practices,  and  associated  challenges.  As  a  representative  from  a  national  authority823 
explained,  there  is  an  absence  of  established  mechanisms  and  processes  for  structured 
exchanges at local and regional levels. As a result, reporting tends to be voluntary rather 
than mandatory, with reporting being sought through friendly reminders and not formal 
requests. The coordination mechanism is characterised as relatively soft in the initial 2000 
strategy,  lacking  a  mandate  for  authorities  to  report.  Reports  from  cities  implementing 
urban  adaptation  plans  were  received  in  2019,  but  the  reporting  primarily  pertained  to 
urban sectors. An interviewee did not specify the mentioned strategy. 

Further insights specifically related to the NECP development process were gleaned from 
representatives of a national authority during a case study interview. 824 It was noted that 
the  primary  challenges  encountered  in  NECP  preparation  are  related  to  workload.  The 
delayed  provision  of  documents  from  the  European  Commission,  coupled  with  a  tight 
timeframe  for  interpretation,  posed  a  significant  hurdle.  Despite  optimism  for  improved 
collaboration in subsequent reports, past experiences underscore the necessity for earlier 
preparation and ample time for interpretation. Tight submission deadlines and extensive 
documentation seemed to exacerbate the situation. 

A  similar  perspective  was  voiced  during  the  stakeholder  event825,  where  the  Ministry  of 
Climate  and  Environment  highlighted  the  late  publication  of  regulations  and  a  time-
consuming  process  as  being  significant  barriers  to  timely  submission  of  NECPs  and 
integrated  progress  reports  and  their  completeness  and  quality.  This  perspective 
underscores  that,  despite  the  potential  benefits,  there  are  hurdles  to  be  addressed  for 
seamless implementation. 

Moreover, the need for request revisions to align with rapidly changing EU goals posed a 
strategic challenge, as Member States faced pressure to agree on targets amid evolving 
circumstances, according to a national authority. The limited time for  reading, applying, 
seeking  cooperation,  and  posing  questions  to  the  European  Commission  further 
complicated  the  process,  despite  the  European  Commission's  willingness  to  assist.  This 
suggests  the  need  for  better  alignment  between  regulatory  requirements  and  practical 
implementation timelines to ensure effective preparation and collaboration in the future. 

EU assistance and guidance in report preparation 

A  national  authority  interviewed  acknowledged  the  valuable  support  from  the  European 
Environment Agency (EEA) in preparing information used for the NECP the report, both at 
the  EU  and  national  levels.  It  was  noted  that  this  help  proved  beneficial,  particularly  in 
addressing specific questions and concerns during the preparation process.826 

Usefulness of templates and platforms including issues in using them 

This  section  draws  on  insights  gathered  from  the  case  study  interviews  with 
representatives from a national authority.827 It examines challenges within the existing 
framework  and  Reportnet  and  delves  into  proposed  improvements  to  the  Reportnet 
system,  advocating  for  a  reporting  experience  that  is  more  cohesive  and  intuitive. 
Throughout, there is a clear emphasis on the significance of providing clear guidance and 
incorporating lessons learned, particularly within the specific context of climate adaptation 

823 Case study interview with a national authority in Poland on 18 January 2024. 

824 Case study interview with a national authority in Poland on 4 March 2024. 

825 Stakeholder event on the Governance Regulation review on 11 January 2024 in Brussels 
826 Case study interview with a national authority in Poland on 18 January 2024. 
827 Case study interviews with a national authority in Poland on 18 January and 4 March 2024. 

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reporting in Poland. Then the focus switches to the user experience with both Reportnet 
and ReportENER systems, offering additional insights on areas for improvement. 

As noted during the case study interview828, the existing framework comprises Reportnet 
and the implementing regulation, both designed to offer a structured format for reporting. 
To clarify, requirements for national reporting on adaptation actions are defined in Article 
19  of  the  Governance  Regulation829.  The  2023  Adaptation  Reporting  Guidelines  by  the 
European Environment Agency (EEA)830 provides guidance for this reporting, as detailed in 
Art. 4 and Annex I of the Implementing Regulation (EU) 2020/1208. Member States were 
required to submit NECPRs by 15 March 2023 and every two years thereafter, as outlined 
in  Annex  III  of  Implementing  Regulation  (EU)  2022/2299,  detailing  the  implementation 
status of their NECPs, in accordance with Article 17(1) of the Governance Regulation. This 
reporting,  including  decarbonisation  and  adaptation  progress  is  conducted  through 
Reportnet 3 dataflow 897.  

Continuing with the feedback received from a national authority, the challenge lies in the 
ambiguity  surrounding  the  specifics  of  information  provision,  exacerbated  by  the 
adaptation  reporting  guidelines.  The  guidelines,  though  attempting  to  delineate  the 
character limits for each field, and an accompanying toolkit, proved less than illuminating. 

For example, a consultancy assessment that a national authority referred to but did not 
specify, shed light on the presence of unanswered questions within the reporting process 
on climate adaptation. These queries pointed towards specific recommendations rooted in 
Article  19,  annex  1,  section  one.  This  revelation  prompted  the  need  to  locate  where 
alterations were required within the Reportnet. 

Navigating  this  task  involved  a  dual  process,  as  explained  by  a  representative  from  a 
national authority.831 First it was necessary to identify the corresponding section within the 
implementing regulation and then the exact field within Reportnet had to be identified. The 
challenge  lies  in  the  fragmented  nature  of  this  information  search,  spread  across  three 
distinct documents and locations. This concern was communicated to the EEA, particularly 
in the context of adaptation working group discussions.  

The  difficulties  experienced  highlight  a  need  for  changes  and  adaptations  to  the 
platform.  According  to  an  interviewed  representative  of  a  national  authority832,  these 
might  include  renaming  fields  or  incorporating  additional  information  on  the  relevant 
sections  of  the  implementing  regulation.  Alternatively,  consideration  could  be  given  to 
dividing the reporting process. This stems from the observation that certain elements, such 
as  pits  and  pads,  do  not  align  with  the  corresponding  sections  in  the  implementing 
regulation. The disparity between sections in the IT systems and those in the implementing 
regulation adds a layer of complexity, as they do not seamlessly align. 

In essence, there is a call for a more cohesive and intuitive system within Reportnet, 
either through improved labelling, segregation of sections, or enhanced guidance on the 
correlation  between  the  reporting  fields  and  the  implementing  regulation.  This  proposal 

828 Case study interview with a national authority in Poland on 18 January 2024. 

829 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action  

830 European Environmental Agency (February 2023). 2023 Adaptation Reporting Guidelines. Documentation and 
help for the 2023 reporting on Article 19 from the Governance Regulation on the Energy Union and Climate action. 
Reporting  on  National  climate  change  adaptation  planning  and  strategies  in  Reportnet  3.  Available  here: 
file:///C:/Users/61501/Downloads/Adaptation%20Reporting%20-%20Documentation%20and%20help.pdf 

831 Case study interview with a national authority in Poland on 18 January 2024. 

832 Case study interview with a national authority in Poland on 18 January 2024. 

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aims to streamline the process, reduce ambiguity, and facilitate a more efficient reporting 
experience for all stakeholders involved. 

On  national  authority  highlighted  during  a  case  study  interview833,  the  importance  of 
guidelines  that  include  examples  or  detailed  explanations,  particularly  regarding 
monitoring.  It  was  noted  that  this  would  help  prevent  inconsistencies  and  varying 
interpretations,  ensuring  a  coherent  approach  to  the  information  provided  by  different 
countries. 

Combining additional feedback 834 received on ReportENER, it is evident that users of both 
Reportnet and ReportENER also encountered difficulties arising from inadequate time for 
familiarisation, absence of editable tables provided by the European Commission for data 
collection, and restrictions on comments in fields, allowing only numerical input. This lack 
of  flexibility  posed  challenges  as  national  data  had  to  adhere  to  specific  formats  not 
accommodated by the input fields. The technical complexity of the systems, coupled with 
a lack of hyperlinks for navigation are potential areas for improvement. 

Insights from the case study interviews in Poland point to the need for a comprehensive 
approach to improving reporting systems. This includes enhancing the user interface 
for better usability, and offering clear guidance with examples to ensure consistency across 
reporting. These improvements aim to create a more efficient, intuitive, and user-friendly 
reporting experience for all stakeholders involved. 

Main benefits  

This section explores the potential benefits of the regulatory shifts led by the Governance 
Regulation  in  Poland.  It  explains  the  benefits  of  the  Governance  Regulation’s  impact  on 
reporting practices in Poland, particularly on adaptation to climate change. 

The case study interviews in Poland have revealed the role the Governance Regulation has 
played in enhancing coordination mechanisms for climate change adaptation reporting. For 
instance,  one  national  authority  explained  that  before  the  Governance  Regulation, 
reporting to the European Commission primarily focused on CO2 emissions, rather than on 
adaptation to climate change. The stakeholder explained that the Governance Regulation 
has helped to address this notable gap. 

Prior  to  the  Governance  Regulation,  the  lack  of  comprehensive  national  plans  and  the 
isolated functioning  of  sectors such  as agriculture, health, and transport highlighted the 
necessity for a more integrated approach. While a list of adaptation actions existed, there 
was no recurring requirement to report every year or two. According to a national authority 
from  Poland,  the  prospective  role  of  Governance  Regulation  is  poised  to  guide  the 
establishment  of  a  coordinated  strategy,  making  reporting  on  adaptation  a  recurring 
requirement.  This,  in  turn,  emphasises  the  necessity  for  external  support  and  input  to 
ensure accurate and effective reporting. 

Data from the targeted survey of national authorities indicates a nuanced perspective from 
respondents in Poland. On the one hand, there was agreement that an equivalent level of 
planning could have been reached even in the absence of the Governance Regulation. While 
national  authorities  held  divided  opinions  on  whether  the  Governance  Regulation  has 
facilitated access to information in Poland that would otherwise have been inaccessible to 
the  public,  they  also  harboured  differing  views  on  whether  the  Regulation  has  provided 
access  to  information  from  other  Member  States  that  would  otherwise  not  have  been 
available to their relevant national authorities. No other stakeholder groups shared their 

833 Case study interview with a national authority in Poland on 18 January 2024. 

834 Case study interview with a national authority in Poland on 4 March 2024. 

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views  on  these  aspects.  Building  on  these  insights,  the  case  study  interviews  offer  a 
glimpse  into  the  potential  advantages  of  the  Governance  Regulation.  Some 
interviewees  from  a  national  authority  highlighted  time  savings  in  reporting  on  climate 
change adaptation. Anticipating a streamlined process, the availability of readily accessible 
information from stakeholders is expected to improve efficiency in compilation and access, 
thereby  fostering  increased  coherence  in  planning,  reporting  timelines,  and  procedures. 
Moreover,  it  is  expected  that  the  Governance  Regulation  will  catalyse  internal 
improvements within ministries, fostering the development of more established processes, 
policies, and procedures over time. Although there was recognition from stakeholders of 
initial progress in this direction, they also mentioned that the full benefits will take time to 
fully materialise. This view was echoed by representatives from a  national authority  in 
the case study interviews.  

Representatives  from  an  interviewed  national  authority  mentioned  that  collaboration 
among and between ministries and stakeholders has been enhanced, partly during NECP 
preparation, but also due to other factors external to the Governance Regulation, such as 
digital integration post COVID-19. External events, like the Russian invasion of Ukraine, 
have further spurred collaboration.  

A  national  authority  also  explained  that  the  NECP  for  Poland  aims  to  embrace  a 
comprehensive approach, treating the entire economy as a unified entity to ensure policy 
alignment in addressing energy and climate complexities. It was identified that although 
immediate time savings may not be obvious, the NECP promises long-term benefits. The 
heightened public interest in energy and climate also underscores the importance of clear 
communication on these topics. Despite challenges, engagement with the NECP is seen by 
a national authority as rewarding, highlighting the value of transparent and more efficient 
communication in garnering public support for climate initiatives. 

A5.6.3. Public consultation and multilevel climate and energy dialogues  

This section provides an overview of the following areas835: 

  Public consultation on National Energy and Climate Plan (NECP): timing, description 

of the design and implementation of the process 

  Outcomes of the public consultation on NECP 
  Multi-level Energy and Climate Dialogues (MECDs) 

Public consultation  

A consultation on the draft NECP  for Poland was conducted between  14 January and 18 
February 2019 following its publication with a deadline set after the public consultation on 
the draft Energy Policy for Poland until 2040.  836 Responses to a consultation on the draft 
NECP were accepted though until the end of March 2019.837 

The draft was made public on the Ministry of Energy's website. The Ministry of State Assets 
(formerly the  Ministry of Energy) invited the public to submit opinions, and the Ministry 
received approximately 1100 comments from around 80 parties, including seven ministries 

at: 

835  The  National  Energy  and  Climate  Plan  for  2021-2030  Objectives  and  targets,  and  policies  and  measures. 
Available 
https://commission.europa.eu/energy-climate-change-environment/implementation-eu-
countries/energy-and-climate-governance-and-reporting/national-energy-and-climate-plans_en 
836 European Commission (June 2019) Staff Working Document. Assessment of the draft NECP. Available here: 
https://energy.ec.europa.eu/system/files/2019-06/pl_swd_en_0.pdf 

837 European Commission (October 2020) Staff Working Document. Assessment of the final national energy and 
climate 
https://energy.ec.europa.eu/system/files/2021-
here: 
01/staff_working_document_assessment_necp_poland_en_0.pdf 

Available 

Poland. 

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and four offices, all major energy sector State Treasury companies, transmission system 
operators,  industry  associations,  NGOs,  local  governments,  and  individuals  interested  in 
the subject. The comments were detailed, expert, or technical in nature, with a focus on 
decarbonisation,  renewable  energy  sources,  energy  efficiency,  the  heating  sector, 
cogeneration, energy security, network infrastructure, alternative fuels in transport, and 
more, according to the report.838 These outcomes reflect a broad and detailed engagement 
from various stakeholders in shaping the NECP. 

According to the European Commission assessment839 of the final NECP submitted in 2019, 
Poland has not provided an in-depth overview of the public's perspectives and the extent 
to  which  they  have  been  incorporated  into  the  NECP,  despite  asserting  that  the  plan 
integrates feedback from the public consultation process. Most comments focused on topics 
such  as  emissions  reductions,  renewables,  energy  efficiency,  and  security  of  supply. 
Additionally,  there  is  an  emphasis  on  the  significance  of  investments  in  networks, 
particularly at the distribution level, and the importance of energy storage. Notably, there 
is no indication that a strategic environmental assessment (SEA) has been conducted on 
the NECP, as required by Directive 2001/42/EC. 

During the desk research and stakeholder consultation, no specific information was found 
or  made  available  on  the  extent  of  costs  involved  in  the  consultation  process.  Limited 
feedback  from  targeted  interviews  with  a  third  sector  stakeholders  suggests  potential 
obstacles  to  this  process.  It  was  indicated  that  consultations  are  often  undertaken  as  a 
mere  obligation,  with  little  practical  value  if  conducted  hastily,  such  as  within  a  10-day 
timeframe.  Furthermore,  it  poses  a  challenge  for  Polish  local  and  regional  authorities  to 
have the necessary capacity.  

The  recently  released  draft  updated  NECP 840  is  expected  to  undergo  thorough  public 
consultation  and  sectoral  arrangements  before  reaching  finalisation  in  the  transition 
between Q2 and Q3 of 2024. 

As mentioned in section 1.1, Poland has not submitted its national LTS. 

Multi-level Energy and Climate Dialogues (MECDs) 

The European Commission in its assessment841 of the final NECP submitted in 2019 urged 
Poland to better exploit the potential of the MECDs, actively involving regional and local 
authorities, social partners, civil society organisations, the business community, investors, 
and other pertinent stakeholders. The aim is to engage in discussions with these groups 
regarding the various scenarios envisioned for the country's energy and climate policies. 

at: 

838  The  National  Energy  and  Climate  Plan  for  2021-2030  Objectives  and  targets,  and  policies  and  measures. 
Available 
https://commission.europa.eu/energy-climate-change-environment/implementation-eu-
countries/energy-and-climate-governance-and-reporting/national-energy-and-climate-plans_en 
839 European Commission Staff Working Document (October 2020). Assessment of the final national energy and 
climate 
https://energy.ec.europa.eu/system/files/2021-
at : 
Poland. 
01/staff_working_document_assessment_necp_poland_en_0.pdf  

Available 

plan 

of 

840 Ministry of Climate and Environment. National Plan in the field of Energy and Climate by 2030 (2019 update 
of  NECPs).  Preliminary  version.  Available  here:  https://commission.europa.eu/document/download/5118b15e-
d380-49ae-b8bb-41cc81a28e15_en?filename=PL_NECPupdate_Projekt_EN.pdf  

841 European Commission Staff Working Document (October 2020). Assessment of the final national energy and 
climate 
https://energy.ec.europa.eu/system/files/2021-
at : 
Poland. 
01/staff_working_document_assessment_necp_poland_en_0.pdf  

Available 

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A5.6.4. Regional cooperation 

This  section  provides  information  on  the  collaborative  efforts  between  Poland  and  other 
countries leading up to the submission of the Polish NECP. It delves into the scope of this 
cooperation, outlining its key objectives and highlighting the outcomes attained842. 

Experience  with  engaging  in  regional  cooperation  before  submitting  the  NECP,  including 
the underlying reasons 

Between  8  and  30  August  in  2019,  regional  consultations  were  conducted  on  the  draft 
NECP  as  required  by  Article  12  of  the  Governance  Regulation.  Written  comments  were 
sought  from  eight  countries,  including  the  Visegrad  Group  (V4,  i.e.  Czechia,  Slovakia, 
Hungary),  countries  with  transboundary  connections  (Germany,  Sweden,  Lithuania), 
Denmark (related to the Baltic Pipe investment), and Romania.  

The engagement aimed at gathering insights from neighbouring and other countries on the 
draft  NECP,  understanding  regional  perspectives,  and  fostering  bilateral  cooperation, 
particularly  within  the  energy  working  group,  as  well  as  addressing  shared  regional 
challenges. As noted in the final NECP submitted by Poland in 2019 843, Hungary expressed 
support for Poland's goals and interests, particularly in the creation of a gas transmission 
and trading hub and the construction of the North-South corridor. The remaining countries 
either communicated that they had no comments or did not submit any comments. The 
draft plan was also subject to consultations with the Baltic energy market interconnection 
plan (BEMIP) High Level Group in 2019,  of which Poland is  a member. According to the 
European Commission’s assessment844 of the final NECP, submitted in 2019, Poland has 
been rather pro-active in this group. Poland was invited to continue these ongoing efforts 
to  intensify  exchanges  and  initiatives  that  will  facilitate  the  implementation  of  its  NECP, 
particularly as regards relevant cross-border issues. Poland is also invited to better exploit 
the potential of the multilevel climate and energy dialogues to actively engage with regional 
and  local  authorities,  social  partners,  civil  society  organisations,  business  community, 
investors and other relevant stakeholders, and to discuss with them the different scenarios 
envisaged for its energy and climate policies.  

In its assessment of the final NECP of Poland, the European Commission underlined that 
the recommendations on regional cooperation based on the draft NECP have been fully or 
largely addressed by Poland in its final NECP, as described in Table A6.20.    

Table 59.  European  Commission  assessment  of  the  final  NECP  of  Poland:  regional 

cooperation  

Recommendation  on 
cooperation 

regional 

Status 

European 
assessment  

Commission’s 

and 

the 
Continue 
consultation  of  neighbouring  Member 
States and regional cooperation in the 
context of the 

broaden 

Fully 
addressed 

Poland received a recommendation to 
reinforce  regional  cooperation  and  it 
fully addressed this recommendation. 
added 
Specifically, 
consulting 
information 

Poland 

about 

at: 

842  The  National  Energy  and  Climate  Plan  for  2021-2030  Objectives  and  targets,  and  policies  and  measures. 
https://commission.europa.eu/energy-climate-change-environment/implementation-eu-
Available 
countries/energy-and-climate-governance-and-reporting/national-energy-and-climate-plans_en 
843  The  National  Energy  and  Climate  Plan  for  2021-2030  Objectives  and  targets,  and  policies  and  measures. 
Available 
https://commission.europa.eu/energy-climate-change-environment/implementation-eu-
countries/energy-and-climate-governance-and-reporting/national-energy-and-climate-plans_en  
844 European Commission Staff Working Document (October 2020). Assessment of the final national energy and 
climate 
https://energy.ec.europa.eu/system/files/2021-
at : 
Poland. 
01/staff_working_document_assessment_necp_poland_en_0.pdf  

Available 

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Recommendation  on 
cooperation 

regional 

Status 

European 
assessment  

Commission’s 

Visegrad  Group  (Czechia,  Hungary, 
Poland  and  Slovakia)  and  in  the 
respective high-level groups. 

neighbouring  Member  States  in  its 
final  NECP  compared  to  the  draft. 
Consultations were carried out on the 
NECP  with  the  Visegrad  countries, 
countries  with  a  common  border 
(Germany,  Sweden,  and  Lithuania) 
and Denmark and Romania, as well as 
the BEMIP High Level Group, of which 
Poland  is  a  member.  Poland  also 
describes  cooperation  within 
the 
Visegrad  group,  highlighting  that 
countries aim to create a regional gas 
market,  cooperating  on  energy  and 
nuclear  energy,  with  the  goal  of 
ensuring energy security. 

The  focus  of  the  regional  exchanges 
could be on further integration in the 
internal  energy  market,  assessing 
system  adequacy  in  light  of  the 
planned  continuation  of  a  capacity 
issues, 
market, 
just 
decarbonisation 
renewables 
deployment  and  the  impact  on  the 
energy  system  and  cross  border 
electricity trade. 

transition 

and 

Largely 
addressed 

further 

integrate  the 

The  assessment  acknowledges  that 
the necessity for regional cooperation 
to 
internal 
energy  market  is  well  understood. 
Poland describes existing and planned 
electricity 
cooperation 
infrastructure 
the 
transmission  capacities  of  cross 
border  interconnections)  and  energy 
transmission  networks  (integrating 
the networks of the Baltic states and 
the North-South Corridor projects). 

on 
(increasing 

Statistical transfers to/from other EU 
Member  States  and  joint  energy 
projects  are  also  mentioned,  but 
these are still ideas without concrete 
details. 

Poland describes in detail the planned 
impact of its policies and measures on 
neighbouring 
States 
(chapter 5.4). 

Member 

The  plan  lacks  detail  on  cooperation 
in decarbonisation and just transition 
polices. 

Source:  European  Commission  (October  2020)  Staff  Working  Document.  Assessment  of  the  final 
national energy and climate plan of Poland 

Feedback  given  during  the  targeted  survey  of  national  authorities  indicates  that  Poland 
took advantage of, or has increased its cooperation with other Member States, at least to 
some extent. Such a consensus was reached by 11 national authorities across 17 Member 
States  in  response  to  the  relevant  question.  This  inquiry  specifically  addressed 
development  of  national  plans,  such  as  NECPs,  and  the  design  of  national  energy  and 
climate policy. 

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A5.6.5. Compliance mechanisms  

This section focuses on Poland's progress in addressing the recommendations put forth by 
the European Commission on the draft integrated NECP. Due to Poland's late submission 
of  the  draft  updated  NECP  beyond  the  stipulated  deadline,  the  European  Commission's 
subsequent assessment is not available at the time of writing. 

In June 2019, the European Commission issued ten recommendations845 for Poland’s final 
plan.  The  evaluation  of  how  each  of  them  has  been  tackled  in  Poland's  final  NECP  is 
conducted  in  the  European  Commission's  assessment.846  According  to  this  assessment, 
overall, 
the  European  Commission’s 
recommendations. The list of these initial 10 recommendations expands into 26 individual 
more detailed recommendations, of which three have been fully, five largely  addressed, 
15 partially addressed, and three not addressed. An overview across various topics, except 
for regional cooperation which was previously discussed, is provided in the table below.  

the  NECP  partially  addresses  most  of 

Table 60.  European Commission’s assessment of the final NECP of Poland  

Topic  

Number  and  status  of 
recommendations 

Summary  of  European  Commission’s 
assessment (2020)  

Decarbonisat
ion 

– GHG 

3 recommendations: 

1 largely addressed 

1 partially addressed 

1 not addressed 

has 

partially 

addressed 
Poland 
recommendations  by  providing  more 
information  on  planned  policies  and 
measures in sectors such as transport to 
meet its greenhouse target. Other sectors 
like 
heating, 
agriculture,  and  LULUCF  will  have 
separate strategies outlined, although the 
plan offers only a general perspective. 

buildings, 

district 

Decarbonisat
ion 
- 
renewables 

7 recommendations: 

2 fully addressed 

5 partially addressed  

While  Poland  has  included  an  indicative 
trajectory  and  detailed  policies  and 
measures, its ambition level to reach the 
EU  target  for  2030  remains  below  the 
recommended 25%. The plan outlines an 
indicative trajectory with expected shares 
of  renewables  but  lacks  detailed  policies 
and measures for achieving these targets.  

Energy 
efficiency 
target 

4 recommendations: 

1 largely addressed 

2 partially addressed 

1 not addressed 

New  policies  on  energy  efficiency  in 
transport  have  been  introduced,  but 
overall  ambition  remains  unchanged. 
Although 
in 
is 
information  regarding  buildings,  long-

improvement 

there 

845 European Commission. Staff Working Document (June 2019). Assessment of the draft National Energy and 
Climate  Plan  of  Poland.  Available  at:  https://energy.ec.europa.eu/document/download/cdb5e342-e932-423d-
90a0-abd05bacf333_en  
846 European Commission Staff Working Document (October 2020). Assessment of the final national energy and 
climate 
https://energy.ec.europa.eu/system/files/2021-
Poland. 
01/staff_working_document_assessment_necp_poland_en_0.pdf 

Available 

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Energy Union and Climate Action 

term  renovation  strategies  are  pending 
submission. 

The  plan  describes  measures  supporting 
objectives on diversification and reduction 
of energy dependency but lacks adequate 
links  with  emergency  plans  for  gas, 
electricity, and oil. Certain obligations on 
gas 
import  companies  are  seen  as 
conflicting with sectoral rules. 

While  objectives  and  targets  for  market 
integration  are  defined,  clarity  is  lacking 
regarding impacts on market functioning 
and  concrete  steps  to  mitigate  negative 
effects. 

Objectives  to  increase  R&D  expenditure 
to 2.5% of GDP by 2030 are outlined, but 
concrete  measures  are  needed.  Specific 
2050 national objectives for clean energy 
technologies are missing. 

Energy 
security 

1 recommendation: 

1 largely addressed  

Internal 
energy 
market 

1 recommendation: 

1 partially addressed 

1 recommendation: 

1 partially addressed 

Research, 
innovation, 
and 
competitiven
ess 

Energy 
subsidies 

3 recommendations: 

1 largely addressed 

2 partially addressed 

Plans  to  phase  out  certain  fossil  fuel 
subsidies,  including  state  aid  for  closing 
coal  mines,  are  included,  along  with 
mention of a new capacity mechanism. 

Air quality 

1 recommendation: 

1 partially addressed 

Just 
transition 
and  energy 
poverty 

3 recommendations: 

2 partially addressed 

1 not addressed 

is  partially 
Analysis  of  air  quality 
addressed,  but 
interaction  between 
proposed policies and measures and their 
impact on air pollutant emissions are not 
thoroughly described. 

just 

While recognition is given to the need for 
transition 
thorough  analysis  of 
aspects,  particularly  in  mining  regions, 
and  ongoing  initiatives  are  reported  for 
addressing  energy  poverty,  depth  in 
analysis  and  quantification  of  challenges 
are 
lacking,  with  ongoing  work  on 
indicators. 

Source:  European  Commission  (October  2020)  Staff  Working  Document.  Assessment  of  the  final 
national energy and climate plan of Poland 

According  to  a  national  authority  that  was  interviewed 847,  anticipated  challenges  in 
implementing the European Commission's recommendations include areas where there is 
a lack of specific information or decisions in certain instances at national level coupled with 
the  difficulty  in  addressing  every  issue  at  a  high-level  due  to  complexity.  The  feedback 

847 Case study interview with a national authority in Poland on 4 March 2024. 

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underscores that addressing all issues at a high level seems unfeasible, whereas achieving 
perfection  demands  time.  While  striving  for  perfection  might  lead  to  unrealistic  targets, 
such  as  larger  renewables  goals  suggested  by  the  European  Commission,  a  national 
authority  prioritises  adequacy  which  is  aimed  for  in  the  approach,  grounded  in  practical 
analysis rather than arbitrary figures and commitment to regular updates reflecting reality. 
Drawing  on  lessons  learned,  preparation  for  the  anticipated  challenges  posed  by  the 
European Commission's recommendations is acknowledged.  

As noted earlier, at the time of writing, Poland has not yet submitted its national LTS to 
the European Commission.  

A5.6.6. Lessons learned and recommendations  

Comprehensive insights into the intricacies of the reporting process on climate adaptation 
were  provided  during  an  interview  with  a  national  authority  from  Poland.848  The 
stakeholder  mentioned,  for  example,  the  importance  of  enhanced  coordination  and 
collaboration  with  local  and  regional  authorities,  as  well  as  other  ministries 
overseeing diverse facets of  climate adaptation. The  reporting schedule, which does not 
seamlessly  align  with  existing  obligations  in  Poland,  is  seen  as  challenging.  This 
misalignment prompts  considerations about adjusting reporting timelines to synchronise 
with regional and sectoral reporting cycles. 

National  authorities  also  explained  that  adaptation  to  climate  change  is  not  sufficiently 
emphasised in the Governance Regulation.849 Attention was drawn to the NECPs, and the 
somewhat peripheral and fragmented nature of climate adaptation within these plans.  

National authorities questioned the  sequencing of actions within the adaptation strategy 
and the NECP. This complexity arises from uncertainties about whether actions outlined in 
the  NECP  need  to  be  revisited  when  updating  the  adaptation  strategy.  The  dilemma 
extends to discerning the European Commission's expectations regarding the inclusion of 
adaptation information in the national energy and climate plan. Amidst these complexities, 
was  given  to  the  international  and  national  dimensions,  raising  queries  about  the 
precedence  of  actions  and  potential  conflicts  arising  from  disparities  in  timelines  for 
updating the NECP and the national adaptation strategy.850 

On  another  occasion 851,  representatives  from  a  national  authority  made  a  proposal  on 
regional  cooperation.  It  was  suggested  that  coordinating  regional  meetings  through  the 
European  Commission  could  provide  a  more  effective  approach.  This  would  allow  for  a 
deeper understanding of specific regional issues and a more level playing field, ensuring 
equal  participation  across  countries,  and  facilitating  a  more  collaborative  exchange  of 
ideas. 

848 Case study interview with a national authority in Poland on 18 January 2024. 
849 Case study interview with a national authority in Poland on 18 January 2024. 
850 Case study interview with a national authority in Poland on 18 January 2024. 

851 Case study interview with a national authority in Poland on 4 March 2024. 

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Table 61.  List of stakeholders consulted for the case study in Poland 

Stakeholder type 

Authority 

National authority 

Department  of  Air  Protection  and 
Urban  Policy,  Ministry  of  Climate 
and Environment 

Interview date  

18 January 2024 

National authority 

Energy  Policy  Unit,  Department  of 
Strategy  and  Analyses,  Ministry  of 
Climate and Environment 

 4 March 2024 

Table 62.  Documents reviewed  

Document type 

Author(s) and title 

Year 

NECP 

Ministry of Energy. Draft of the Integrated National 
Energy and Climate Plan for the years 2021-2030 

January 
2019 

Staff 
Document 

Working 

European  Commission.  Staff  Working  Document. 
Assessment of the draft NECP 

June 2019 

NECP 

The  National  Energy  and  Climate  Plan  for  2021-
2030.  Objectives  and  targets,  and  policies  and 
measures.  

December 
2019 

Staff 
Document 

Working 

European  Commission  Staff  Working  Document. 
Assessment of the final national energy and climate 
plan of Poland 

October 
2020 

Guidelines 

European  Environmental  Agency.  Adaptation 
Reporting  Guidelines.  Documentation  and  help  for 
the  2023  reporting  on  Article  19 
from  the 
Governance  Regulation  on  the  Energy  Union  and 
Climate  action.  Reporting  on  National  climate 
change  adaptation  planning  and  strategies  in 
Reportnet 3.  

February 
2023 

Factsheet 

European  Commission.  State  of  the  Energy  Union 
2023 Poland 

October 
2023 

NECP 

Ministry of Climate and Environment. National Plan 

March 2024 

in  the  field  of  Energy  and  Climate  by  2030  (2019 
update of NECPs). Preliminary version. 

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A5.7. Case Study – Romania 

A5.7.1. Background  

In  Romania,  the  responsibility  for  addressing  climate  change  is  shared  between  the 
Romanian  Government  and  42  local  government  authorities  (including  Bucharest).  Until 
2022, the Ministry of Environment, with the Ministry of Energy, was the lead authority in 
the  Romanian  Government’s  responses  to  climate  change852.  Thanks  to  the  technical 
assistance  service  offered  by  DG  REFORM  (TSI  instrument),  a  dedicated  governance 
structure/department responding directly to the Prime Minister was set up, with the main 
role  to  develop,  implement  and  monitor  all  strategies  to  respond  to  and  limit  climate 
change. Normally, the update of the NECP and the development of the LTS should have 
been followed by the afore-mentioned department. Unfortunately, however, some issues 
arose  which  prevented  the  updating  and  reporting  of  the  NECP  in  that  dedicated 
governance  structure/department.  Responsibility  to  update  the  NECP  was  therefore 
assigned  to  the  Ministry  of  Energy  (appointed  by  an  emergency  ordinance),  while  the 
development  of  the  Long-Term  Strategy  (LTS)  was  assigned  to  the  Ministry  of 
Environment. This resulted in delays in both processes853.  

The Romanian LTS was only released on 5 May 2023, three and a half years late. It was 
prepared  by  a  contractor,  PwC,  and  published  for  public  consultation  by  the  National 
Competent Authority (i.e. the Ministry of Energy and Ministry of Environment, Waters and 
Forests).  

Like the first NECP, which was due by 31 December 2019 and only submitted in April 2020, 
the draft NECP update, due by 30 June 2023, was also submitted with a delay. This was 
because, following the emergency ordinance, the Ministry of Energy had the necessity to 
hire an external consultant. Only the University of North Macedonia (UoNM) participated in 
the  bid,  with  no  previous  expertise  in  working  with  NECPs  at  EU  level.  The  UoNM 
commenced work in May/June 2023. At that point, the  Ministry  of Energy together with 
the consultant set up  an interinstitutional working group  for the  NECPR (submitted with 
delays in the summer 2023) and subsequently focused on the updating of the NECP, which 
was finally submitted in October 2023. 854 Due to the late submission of Romania’s draft 
NECP update, the European Commission has had limited time to draft its assessment and 
prepared the related recommendations six months before the deadline for the final NECP 
update, as required by Article 9(2) of the Governance Regulation.855 

According to the European Commission’s assessment, while it references revised energy 
and climate targets, the draft updated NECP lacks clarity on how these will be achieved, 
particularly  regarding  GHG  emissions  reductions.  The  plan  falls  short  in  addressing  the 
Land  Use  and  Forestry  sector  targets,  lacks  quantification  of  policy  impacts,  and  lacks 
ambition  in  some  areas  such  as  energy  efficiency  and  renewable  energy.  Adaptation  to 
climate  change  is  inadequately  analysed,  and  there  is  a  lack  of  specificity  in  research, 
innovation, and just transition measures. Funding sources and investment needs are poorly 
specified,  and  detailed  strategies  for  R&I  actions  are  absent.  Overall,  the  plan  requires 
more detailed quantitative analysis and strategic alignment with other planning tools.856 

852 Romania’s Eight National Communication under the UNFCCC  
853 Interview with Romanian Ministry of Energy 
854 Interview with Romanian Ministry of Energy 
855 COMMISSION RECOMMENDATION of 18.12.2023 on the draft updated integrated national energy and climate 
plan of Romania covering the period 2021-2030 and on the consistency of Romania's measures with the Union’s 
climate-neutrality objective and with ensuring progress on adaptation, European Commission 
856 COMMISSION STAFF WORKING DOCUMENT: Assessment of the draft updated National Energy and Climate 
Plan of Romania 

September, 2024 

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Energy Union and Climate Action 

The figure below summarises the general goals of the first NECP (published in 2020), and 
then  of  the  draft  NECP  update  (October  2023),  and  their  assessment  by  the  European 
Commission. 

Figure 61. Overview of the goals  of the first NECP (April  2020) and their assessment by 

the European Commission857 

857  COMMISSION  STAFF  WORKING  DOCUMENT  Assessment  of  the  final  national  energy  and  climate  plan  of 
Romania, European Commission, 2020 

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Table 63.  Overview  of  the  goals  of  the  draft  NECP  update  (October  2023)  and  their 

assessment by the European Commission 

The  European  Commission’s  assessment  of  the  draft  NECP  update  highlights  that  “the 
Romanian contribution to the EU 2030 renewables target is unambitious when compared 
to the share resulting from the formula in Annex II to the Governance Regulation. Similarly, 
the Romanian contribution to the 2030 energy efficiency target is assessed to be of low 

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ambition  (in  primary  energy  consumption)  and  of  very  low  ambition  (in  final  energy 
consumption).  Romanian’s  plan  therefore  leaves  plenty  of  space  to  further  develop  and 
strengthen  policies  and  measures  on  both  renewables  and  energy  efficiency  so  as  to 
contribute more to the EU climate and energy targets and strengthen the green transition. 
[…]  Without  specific  adaptation  policies  and  measures,  planned  and  implemented,  the 
achievement of objectives in Energy Union dimensions is at risk” 858. 

As of the latest assessment, fossil fuels still pay a considerable role in the Romanian energy 
mix, with a slight decrease in gas and larger decrease in coal use, but an increase in oil 
consumption. While renewable energy is envisioned to support in Romania’s decarbonising 
process, more efforts are expected to reach common EU goals.859  

A5.7.2. Main costs and benefits of the Governance Regulation  

Main costs  

According to the Romanian Government, the entire working group includes more than 70 
representatives from all institutions with responsibilities in implementing and monitoring 
the policies and measures included in the NECP, according to the emergency ordinance. 
Out of these, not all have the same level of dedication and commitment. Some ministries 
(e.g. Ministry of Transport) even organised internal working groups, while others were less 
responsive. Some members of the working group also act as reporters. In the Ministry of 
Energy, the dedicated team consists of around 10 people, of which 2-3 are working full-
time  on  the  NECP.  As  the  Ministry  of  Energy  does  not  have  a  dedicated  department, 
coordinating  the  working  group  is  a  resource-intensive  task.  It  could  be  argued  that,  in 
terms of time and resource needs, the Romanian Government found it difficult to adapt to 
the new process. However, after some time needed for adapting, now it is clear that it is 
more effective to have a common reporting process.  

However, notwithstanding the effort, the national authorities in Romania are very satisfied 
with  the  support  offered  by  the  European  Commission.  The  European  Commission  was 
responsive and ready to help also with technical issues (e.g. the reporting platform already 
closed  when  Romania  had  the  updated  NECP  ready).  The  short  tutorial  videos  with 
guidance on how to use the platform were particularly helpful. National authorities were 
equally  satisfied  with  the  guidance  offered  by  the  EEA,  who  organised  some  guiding 
workshop  on how to complete information on the platforms.  However, the EEA platform 
proved more difficult to use (e.g. difficult to upload files, frequent crashes, data had to be 
re-entered many times).  

The consulted national authorities were unable to provide a view on the adequacy of the 
costs stemming from the production of Romania’s national LTS.  

Main benefits  

During  the  consultation,  national  authorities  in  Romania  highlighted  the  clear  benefits 
brought  about  by  the  Governance  Regulation.  They  explained  that  the  process  was 
extremely useful because it allowed different services to work more closely together and 
integrate some streams of work. When the Ministry of Energy started working closely with 
the Ministry of Transport, some inconsistencies in reporting were spotted and this allowed 
the streamlining of processes and aligning of trajectories.  

However,  according  to  non-governmental  stakeholders,  the  energy  and  climate  policy 
making process at the national level does not seem to have improved in recent years in 

858 Commission Recommendation of 18.12.2023 on the draft updated integrated national energy and climate plan 
of  Romania  covering  the  period  2021-2030  and  on  the  consistency  of  Romania's  measures  with  the  Union’s 
climate-neutrality objective and with ensuring progress on adaptation, European Commission 
859 State of the Energy Union Romania 2023 

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terms  of  transparency  or  inclusiveness. 860  The  cause  may  lay  in  the  difficulties  the 
Romanian government experienced, as explained at the beginning of this case study. The 
general  feeling  is  that  key  actors,  local  authorities,  civil  society  and  other  stakeholders 
have not been involved throughout the process of NECP updating. This feeling may have 
been exacerbated by the fact the main consultant developing the NECP together with the 
Romanian government is not Romanian and therefore communication and understanding 
of national specificities have been at times difficult.861  

A5.7.3. Public consultation and multilevel climate and energy dialogues 

Public consultation 

Long Term Strategy 

Regarding Romania’s LTS, in the summer of 2022, Romania initiated its development for 
energy and climate evolution until 2050. After crafting eight preliminary scenarios using 
the LEAP_RO model, consultations with the Ministry of Energy (ME) and the Ministry of the 
Environment,  Water  and  Forests  (MMAP)  led  to  a  first  draft  in  November  2022.  The 
Interministerial Committee on Climate Change (CISC) played a pivotal role, with meetings 
in  December  2022  and  February  2023  presenting  targets  and  hypotheses  of  three 
scenarios.  Following  interministerial  consultations,  the  first  full  preliminary  LTS  version 
emerged  on  31  March  2023,  integrating  feedback  from  CISC  institutions.  Further 
consultations ensued between 31 March and 12 April 2023, resulting in a new version by 
18  April  2023.  Bilateral  meetings  with  expert  teams  from  various  ministries  refined  the 
LTS, culminating in the current version on 23 April 2023, which was approved the next day 
at the CISC meeting (24 April 2023). Public engagement commenced on 18 April 2023 and 
included a roundtable at MMAP premises on 27 April 2023. Concurrently, training sessions 
on the LEAP_RO model were held from February to March 2023, involving representatives 
from key governmental bodies. In summary, this means that the consultation process was 
mainly an internal one amongst Romanian ministries, lacking the involvement of a wider 
public,  with  varied  stakeholders  and  open,  inclusive  and  transparent  consultation 
mechanisms. 

NECP 2019 

The process to draft the 2019 NECP followed three steps: 

1.  The  involvement  of  the  National  Parliament:  During  the  public  consultation  from  29 
November to 10 December 2018, the Ministry of Economy submitted an information letter 
to the Presidents of the Senate Chamber and Chamber of Deputies on 5 December 2018. 
However, no official response from these institutions was received by the time of the latest 
version of the draft NECP. 

2. Involvement of Local and Regional Authorities: The Ministry of Energy initiated the public 
consultation by submitting the draft NECP to collect suggestions and opinions that could 
be  considered  recommendations.  Launched  on  29  November  2018,  the  national  public 
consultation  allowed  stakeholders  to  submit  feedback  until  10  December  2018.  The 
conditions of the public consultation do not seem to be satisfactory to meet the requirement 
of Article 10 of the Governance Regulation, especially in terms of ‘reasonable timeframes 
allowing sufficient time for the public to be informed, to participate and express its view’, 
as  recognised  by  the  European  Commission    in  its  assessment  that  while  Romania  was 
among the countries which managed to submit its draft NECP before the deadline at the 

860 Interview with market actor  
861 Interview with representative of local authorities 

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end of 2018, this came at a cost – a very limited period for consultations (only ten days), 
a fact which was signalled by most interested stakeholders.862 

3. Consultations with Stakeholders, Social Partners, Civil Society, and the General Public:  
The  public  consultation  involved  various  stakeholders,  as  evidenced  by  the  list  of 
respondents:  Greenpeace  Romania  (07.12.2018),  Deloitte  Consultanta  (10.12.2018), 
World  Wildlife  Fund  (WWF)  (10.12.2018),  Association  of  Large  Industrial  Energy 
Consumers  (ABIEC)  (10.12.2018),  Romanian  Wind  Energy  Association  (RWEA) 
(10.12.2018), Association of Romanian Electricity Suppliers (AFEER) (10.12.2018), ENGIE 
Romania (10.12.2018), SNTGN Transgaz (11.12.2018).  

According  to  the  European  Commission’s  assessment  (2020),  three  rounds  of  public 
consultation were held, from 29 November to 10 December 2018, from 13 February to 15 
March 2019 and from 31 January to 28 February 2020. Romania submitted, in a separate 
document  annexed  to  the  plan,  the  public’s  views  gathered  during  the  consultation.  A 
summary  of  the  numerous  consultations  is  also  included  in  the  plan,  but  details  of  how 
those  views  have  been  taken  into  account  remain  vague,  since  the  plan  states  that  the 
comments and the recommendations gathered have been ‘partially implemented’.863 Apart 
from being mentioned in the agenda of a meeting with the European Commission during 
the consultation phase, there is no indication  of the NECP having undergone a  strategic 
environmental impact assessment under Directive 2001/42/EC. 

NECP 2023 

National authorities explained that because of the delays caused by the emergency orders 
adopted by the Government, assigning the lead on the document to the Ministry of Energy, 
the draft updated NECP was submitted to the European Commission without undergoing 
public consultation. Therefore, the 2023 draft updated NECP does not address in the same 
detail  how/when  the  consultations  were  carried  out,  as  more  information  will  become 
available  only  for  the  final  version.    The  document  already  includes  the  views  of  the 
interinstitutional  working  group  (other  Ministries,  the  Association  of  Municipalities,  the 
Association  of  Cities  and  the  Association  of  Communes)  who  were  constantly  consulted 
during the reporting and updating process. From January 2024 and until 15 March 2024, 
the  Ministry  of  Energy  will  hold  three  rounds  of  public  consultation  (.  Moreover,  they 
already received some comments and observations from stakeholders (other Ministries and 
stakeholders).864 

This  explains  why,  according  to  the  European  Commission’s  assessment  (2023)865,  the 
draft updated NECP lacks details on public participation and consultation processes, with 
stakeholders  potentially  involved  post-draft.  The  Romanian  Government  considers  the 
interinstitutional  working  group  as  its  Climate  and  Energy  Dialogues,  although  it  only 
comprises public entities (national and sub-national authorities), and not entities from the 
private sector (which are heard through the public consultations)866. However, according 
to  interviews  carried  out  with  other  market  actors  “The  biggest  challenge  is  that  the 
consultations are done only to check the box and only because they are mandatory by law. 
The real dialogue is not happening, relevant stakeholders are not involved so the strategy 
is not adapted to the realities in the field/ local context”.867  

862  COMMISSION  STAFF  WORKING  DOCUMENT  Assessment  of  the  final  national  energy  and  climate  plan  of 
Romania, European Commission, 2020 
863  COMMISSION  STAFF  WORKING  DOCUMENT  Assessment  of  the  final  national  energy  and  climate  plan  of 
Romania, European Commission, 2020 
864 Interview with the Ministry of Energy 
865 COMMISSION RECOMMENDATION of 18.12.2023 on the draft updated integrated national energy and climate 
plan of Romania covering the period 2021-2030 and on the consistency of Romania's measures with the Union’s 
climate-neutrality objective and with ensuring progress on adaptation, European Commission 
866 Interview with representative of a national authority. 
867 Interview with a representative of a local authority. 

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Energy Union and Climate Action 

Multilevel climate and energy dialogues  

Romania is one of the six countries participating in the NECPlatform project868, which offers 
support to the Government in setting up a Climate and Energy Dialogue as mandated by 
Article 11 of the Governance Regulation. The responsible partner for Romania is OER, the 
Romanian branch of Energy Cities. The OER has attempted on several occasions to make 
contact with the Romanian Ministry of Energy. However, the only two results so far have 
been the participation of the Ministry in the first round of the dialogue, held in Bucharest 
on the 20 April 2023 (and reported in the Romanian NECPR), and the invitation of OER in 
participating to the interministerial working group.  

The European Commission had invited Romania, in its assessment of the NECP in 2020869, 
to “better exploit the potential of the multilevel climate and energy dialogues to actively 
engage  with  regional  and  local  authorities,  social  partners,  civil  society  organisations, 
business community, investors and other relevant stakeholders and to discuss with them 
the different scenarios envisaged for its energy and climate policies.” 

From  the  information  available  in  the  final  NECP  published  in  April  2020870,  it  does  not 
seem  that  there  were  opportunities  for  stakeholders  and  local  authorities  to  contribute, 
other than in the general public consultation, whose timeframe was very short. This may 
explain why there was no contribution from local authorities.  

A5.7.4. Regional cooperation 

Regional consultations with other Member States are mentioned in the NECP, but details 
on collaboration are lacking. 

The  European  Commission's  recommendations  on  the  NECP  cite  the  need  for  robust 
regional  consultation  processes.  Romania  is  encouraged  to  intensify  cooperation  with 
neighbouring  Member  States  and  within  the  Central  and  Southeastern  Europe  energy 
connectivity  High-Level  Group,  particularly  focusing  on  interconnectivity,  renewables, 
energy  efficiency,  and  internal  market  alignment  to  address  common  challenges  and 
shared  objectives.  It  is  expected  that  Romania  will  outline  a  framework  for  cooperation 
with  other  Member  States  by  2025,  as  mandated  by  Article  9  of  the  revised  Renewable 
Energy Directive (Directive (EU) 2023/2413). Additionally, Romania is urged to continue 
efforts  to  finalize  bilateral  solidarity  arrangements  for  gas  supply  security  with  Hungary 
and Bulgaria.871 

The 2023 draft NECP update, highlighted the context of urgency due to the ongoing War 
in Ukraine, potential market volatility in natural gas and electricity, and the rapid transition 
to Net-Zero. This called for a unified approach through regional cooperation to setting the 
targets  and  policy  proposals  included  in  the  draft  NECP  update.  During  the  preparatory 
phase, the draft NECP update took into account regional and international projects aligning 
with its goals. Policies and legislation with EU-wide impact were integral to drafting National 
Climate  and  Energy  targets.  Romania's  active  participation  in  various  projects 
strengthened  EU  security  of  supply,  RES  deployment,  and  regional  market  integration. 
Specific policies and measures within the draft NECP update reflect Romania's commitment 
to contributing to regional and EU-wide development. Additionally, Romania declared that 
it has also taken part in the high – level dialogue established within the Central and South-
Eastern Europe Connection Initiative (CESEC) which are aimed at increasing furthermore 
the  regional  cooperation  between  the  member  states  and  fulfilling  European  strategic 
objectives.  Moreover,  Romania  partakes  in  planning  future  natural  gas  infrastructure 
projects  within  the  framework  of  the  “Vertical  Corridor”  initiative,  alongside  Bulgaria, 

868 See: https://energy-cities.eu/project/life-necplatform 
869  COMMISSION  STAFF  WORKING  DOCUMENT  Assessment  of  the  final  national  energy  and  climate  plan  of 
Romania, European Commission, 2020 
870 The 2021-2030 Integrated National Energy and Climate Plan, Ministry of Energy (RO) 
871 COMMISSION RECOMMENDATION of 18.12.2023 

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Hungary  and  Greece.  It  is  expected  that  more  cooperation  will  take  place  between  the 
submission of the draft updated NECP and the final updated  NECP, for instance, further 
regional consultation is foreseen during the Strategic Environmental Assessment under the 
ESPOO convention.872 

In  the  Energy  Efficiency  dimension,  the  draft  NECP  update  highlighted  the  active 
participation  of  the  Ministry  of  Energy  in  the  European  project  ENSMOV  Plus  (LIFE 
programme), dealing with the implementation  of Article 7 (now Article 8)  of the Energy 
Efficiency Directive. In Energy Security, the draft NECP update references contributions to 
projects 
(Bulgaria-Romania-Hungary-Austria  corridor),  Eastring,  and 
involvement in the Central and South-Eastern Europe Connection Initiative (CESEC). The 
Energy  Infrastructure  dimension  encompasses  projects  listed  in  ENTSO-E’s  Ten-Year 
Network  Development  Plan  2022  and  relevant  Projects  of  Common  Interest  impacting 
Romania's  grid  infrastructure  development.  Project-specific  measures  from  these 
investment clusters are included in NECP policies. 

like  BRUA 

A5.7.5. Compliance mechanisms  

According to an NGO, the targets included in the updated Romanian NECP are unlikely be 
met:  “The  2025  targets  project  a  rapid  trajectory  of  renewable  capacity  installation. 
However, given the deployment in the last few years and the slow licencing of projects, 
reaching the 2025 target is rather unlikely, as it would mean that 2.5 GW of solar capacity 
and 2 GW of wind need to be installed in 2 years. Given the current legislative environment, 
slow, untransparent licencing, and limited potential profit of RES projects because of taxes, 
merchant RES projects are not attractive.”873 

It was noted during an interview with a national authority that the government envisages 
creating a digital platform for all reporting obligations concerning the fight against climate 
change (therefore not only NECP but also EED reporting and other obligations). This is one 
of the priorities of the Interinstitutional Climate Change Committee responding to the Prime 
Minister.  

The below figure provides a summary of the Commission’s assessment of the draft updated 
NECP of Romania. 

872 Interview with a representative of a national authority. 
873 Energynomics, Aurora Energy Research on Romania’s 2023 revised NECP  

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Table 64.  Summary  of  the  Commission’s  assessment  of  the  draft  updated  NECP  of 

Romania.  

A5.7.6. Lessons learnt and recommendations  

According  to  Government  sources,  the  process  was  highly  beneficial  as  it  facilitated  the 
breakdown of internal silos and enhanced collaboration between services. This shows that 
communication  and  coordination  between  different  services  of  the  government  and 
different administrative levels form the basis of a good NECP, as the plan does not only 
relate to energy and climate but has effects and implications on most policies.  

The process was also very useful in terms of learning. The staff of the ministries involved 
in the reporting process (physically adding the figures in the platforms) are convinced that 
in future rounds everything will be smoother because of the time invested in learning the 

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process, both in terms of using the provided platforms and methodologies, and because of 
the new relationships built with other services. 

However,  sub-national  authorities and non-governmental stakeholders did not  reflect  so 
positively on the process.  

Sub-national authorities do not feel sufficiently acknowledged and believe the Government 
is overstating the ongoing consultation work, which they consider to be a mere box-ticking 
exercise.  In  particular,  they  perceive  that  national  authorities  often  lack  trust  in  the 
capacity and value of the local level, while local authorities struggle to make their voices 
heard  at  the  national  level.  Representatives  from  sub-national  authorities  therefore 
suggest  imposing  consequences  on  the  Member  States  that  fail  to  adhere  to  the 
Governance Regulation to enhance its overall effectiveness.874 

Other  stakeholders  feel  that  the  Government  lacks  knowledge  or  experience  on  certain 
topics, such as the Energy Efficiency First Principle which – they say – is not sufficiently 
considered in Romanian Energy Planning.875  

Table 65.  List of stakeholders consulted for the case study in Romania 

Stakeholder type 

Position/Role 

Interview date  

Counsellor, Climate Strategies and 
Reporting Department 

18/12/2023 

National  Authority  - 
DG 
Impact 
Assessment,  Pollution 
Control  and  Climate 
Change,  Ministry  of 
Environment,  Waters 
and Forests  

National  Authority  – 
Ministry of Energy 

Policy Officer 

National  Authority  – 
Ministry of Energy 

Policy Officer 

8/02/2024 

8/02/2024 

Third 
Organisation 
Romanian 
Cities 

Third 
Organisation 
Romanian 
Cities 

Sector 

Policy Officer 

23/01/2024 

Energy 

Sector 

Policy Officer 

23/01/2024 

Energy 

Industry  Organisation 
- ESCO 

General Manager 

25/01/2024 

874 Interview with representative of Local Authorities 
875 Interview with market actor  

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Table 66.  Documents reviewed  

Document type 

Author(s) and title 

Commission 
Recommendation 

Factsheet 

NECP  

Corrigendum  

NECP  

Communicate 

Year 

2023 

COMMISSION  RECOMMENDATION  of  18.12.2023  on 
the  draft  updated  integrated  national  energy  and 
climate  plan  of  Romania  covering  the  period  2021-
2030 and on the consistency of Romania's measures 
with the Union’s climate-neutrality objective and with 
ensuring 
European 
Commission 

adaptation, 

progress 

on 

Highlights of the Commission’s assessment, European 
Commision 

2023 

The  2021-2030  Integrated  National  Energy  and 
Climate Plan, Ministry of Energy (RO) 

2020 

COMMISSION 
DOCUMENT 
Assessment  of  the  final  national  energy  and  climate 
plan of Romania, European Commission 

STAFF  WORKING 

2020 

Draft Update Integrated National Energy and Climate 
Plan, Ministry of Energy (RO) 

2023 

Romania’s  8th  National  Communication  on  Climate 
Change under the UNFCCC, Beia Consult International 
et al 

2022 

LTS 

National Long Term Strategy of Romania 

 Online Article  

Aurora  Energy  Research  on  Romania’s  2023  revised 
NECP, Energynomics 

2023 

2023 

Document 

Romania’s  Eight  National  Communication  under  the 
UNFCCC 

2022 

Factsheet 

State of the Energy Union Romania 2023 

2023 

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ANNEX 6. SYNOPSIS REPORT 

A6.1. Introduction 

This  Synopsis  Report  summarises  the  consultation  conducted,  and  stakeholder 
feedback  received,  during  ICF’s  study  supporting  the  evaluation  of  the  Governance 
Regulation  (Regulation  2018/1999).  Section  A6.2  presents  the  approach  to  the 
consultation, while Section A6.3 summarises stakeholders’ feedback. 

A6.2. 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.  

A6.2.1. 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 67 below shows the number of stakeholders contacted and consulted. 

Table 67.  Overview of consultation strategy and results 

Stakeholder group 

Consultation  
method 

Stakeholders 
contacted 

Feedback  
received 

EU entities  

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

Semi-structured 
interviews 

online 

5 

5 interviews 

European  Environmental  Agency 
(EEA) 

Semi-structured 
interviews 

online 

2 

2 interviews 

European  Committee  of 
Regions 

the 

Semi-structured 
interviews 

online 

1 

1 interview 

Joint Research Centre (JRC) 

Semi-structured 
interviews 

online 

4 

2 interviews 

Member State national authorities 

Authorities 
planning / reporting obligations 

responsible 

for 

Semi-structured 
interviews 

online 

87 

Online  survey  of  national 
authorities 

7 
(13 
authorities)876 

interviews  
national 

31 survey responses 

Other  national  authorities  and 
agencies 

Semi-structured 
interviews 

online 

140 

2 
(3 national authorities) 

interviews  

Online  survey  of  national 
authorities 

2 survey responses 

Industry stakeholders 

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

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EU-level  and  national  industry 
associations and organisations 

Semi-structured 
interviews 

online 

295 

4 interviews 

17 survey responses  

Online  survey  of  industry 
stakeholders 

Third-sector stakeholders  

Civil  society  organisations  and 
non-governmental  organisations 
(NGOs) 

Semi-structured 
interviews 

online 

79 

Online  survey  of  third-
sector stakeholders 

16 
(15 organisations) 

interviews  

12 survey responses 

Consumer organisations 

Semi-structured 
interviews 

online 

6 

X 

Online  survey  of  third-
sector stakeholders 

Individual experts 

Semi-structured 
interviews 

online 

17 

1 interview 

Online  survey  of  third-
sector stakeholders 

Academic 
research organisations 

institutions 

and 

Semi-structured 
interviews 

online 

55 

3 interviews 

6 survey responses 

Online  survey  of  third-
sector stakeholders 

Trade unions 

Semi-structured 
interviews 

online 

3 

1 survey response 

Online  survey  of  third-
sector stakeholders 

Other stakeholder groups 

International organisations 

Semi-structured 
interviews 

online 

13 

X 

A6.2.2. Results per consultation method 

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

Online interviews 

Forty-four  semi-structured  online  interviews  were  conducted  during  the  evaluation, 
including 10 scoping interviews completed during the inception stage (between July and 
August 2023), and 32 key informant interviews conducted 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. 

Table 68.  Overview of interviews conducted for the case studies 

Case study 

BELGIUM 

Interviews conducted 

National authorities: 5 interviews 

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DENMARK 

FRANCE 

GERMANY 

MALTA 

POLAND 

Third-sector stakeholders: 1 interview 

National authorities: 1 interview 

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 

TOTAL INTERVIEWS CONDUCTED 

36 

The number of scoping interviews conducted matched the evaluation’s target. However, 
only  around  half  the  planned  key  informant  interviews  could  be  conducted.  This  was 
despite  the  strategies  implemented  by  the  team  to  try  and  increase  the  participation 
rate,  which  included  contacting  additional  stakeholders,  asking  stakeholders  for 
references and for resharing our 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  for  not 
participating, although a small minority indicated either not being available or not feeling 
capable to comment on the Regulation.  

Online surveys 

Three targeted online surveys were deployed during the evaluation: 

One survey for national authorities. The survey was disseminated to 219 contacts 
(representing 85 national authorities) and received 20 responses. 

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

One survey for third-sector stakeholders. The survey was disseminated 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’  website 
ran between July and August 2023 and gathered a total of 53 responses from the general 
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%). Nine percent (9%) 

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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  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 
2024.  The  event  included  around  120  representatives  from  Member  States’  national 
authorities, industry organisations, as well as civil society stakeholders. A total of 460 
online  connections877  were  registered  during  the  event,  with  a  peak  viewership 878  of 
174.  

After introductory remarks by the European Commission, ICF 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.  

A6.3. Summarised stakeholder feedback 

A6.3.1. Relevance of the Regulation 

Most consulted stakeholders agreed that the Governance Regulation remains a relevant 
piece  of  legislation  to  govern  EU  climate  action  and  energy  policy  goals.  Interviewed 
stakeholders  generally  indicated  that  the  Governance  Regulation  remains  a  relevant 
instrument,879  although  several  asked  for  it  to  be  updated  in  light  of  recent  EU  and 
international legislative and policy initiatives.880 

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 responding national authorities agreed 
that the Governance Regulation’s provisions and obligations remain relevant and up-to-
date in light of EU legislative developments. This was only true for about a third (4/14) 
of  responding  third-sector  stakeholders.  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.  This  was  also  true  for  the  seven  national  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  introduced 
after  2018  had  significantly  reduced  the  relevance  of  the  Governance  Regulation. 881 
These changes include the adoption of the European Green Deal, the Fit for 55 package, 
the REPowerEU package, the European Climate Law, and the collective commitment to 

877 A viewer can generate more than one connection during the live; e.g. close and reopen the streaming page 
later, this counts as double connection. 
878 Maximum simultaneous unique viewers at a specific moment in time. 
879 Key informant interviews with two EU bodies, one national authority, one individual expert, five civil society 
organisations. 
880 Key informant interviews with one EU body, two national authorities, one individual expert, two research 
organisations, seven civil society organisations. 
881 NGOs (8); Business associations (2); Environmental organisations (3); EU citizen (1); Public authority (2) 
Other (1); Academic (1) 

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a long-term climate neutrality objective. For instance, seven stakeholders highlighted 
elements introduced 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 climate.882 Four respondents 
underlined that the Governance Regulation does not capture nor define the important 
concept of energy sufficiency. 883   

Participants in the stakeholder event generally found that the Governance Regulation, 
and  its  planning  and  reporting  tools,  has  helped  achieve  national  or  EU  energy  and 
climate objectives.884 

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 justice. 885 

Fit for the future 

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

Readiness to respond to changes and crises 

Most  surveyed  third-sector  respondents  (10/13)  indicated  that  the  Governance 
Regulation  has  not  provided  an  adequate  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 purpose.886  

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 a national level. Two interviewed civil society organisations 
indicated  that  climate  adaptation  needs  to  be  better  covered  by  the  Regulation,  with 

882 NGOs (1); Environmental organisations (1); Academic (1) 
883 NGOs (2); Environmental organisations (1); Academic (1) 
884 A majority responded that this was the case to some (38/94) or to a large extent (37/94). 
885 NGOs (3); Environmental organisations (2); Academic (1);  
886 NGOs (4); Business associations (2); Environmental organisations (2); EU citizen (1); Public authority (1) 

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one  arguing  that  climate  adaptation  needs  to  be  mainstreamed  into  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 the diverging practices across Member States in this respect. 

A6.3.2. 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 

Surveyed stakeholders reported that the Governance Regulation has at least somewhat 
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 climate. 887 
A  majority  of  surveyed  stakeholders  also  indicated  that  the  implementation  of  the 
Governance  Regulation  has  at  least  somewhat  contributed  to  their  Member  State 
adopting  or  implementing  policies  or  measures  to  meet  greenhouse  gas  emissions 
commitments in line with the Paris Agreement. 888 

Some  respondents  to  the  Call  for  Evidence  raised  concerns  about  the  absence  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 goal.889 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,  surveyed  stakeholders 
tended to indicate that the Governance Regulation has contributed to some extent. 890 
National authorities represented the large majority of respondents who considered the 
Regulation  to  have  contributed  to  better  information  at  least  ‘to  a  large  extent’. 
Surveyed  stakeholders  generally  found  the  indicators  included  in  national  reports,  in 
accordance  with  the  Regulation,  to  be  at  least  somewhat  helpful  in  tracking  Member 
States’ progress across the five dimensions of the Energy Union.891 

887 Respondents who answered ‘To some extent’ and upwards, including 24 out of 28 national authorities and 
12 out of 17 third-sector stakeholders.  
888 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  somewhat  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. 
889 NGOs (4); Environmental organisations (2); Academic (1)  
890 More than half (55%) of all respondent groups replied with ‘To some extent’. 
891 Three quarters of respondents (49/64) answered with ‘To some extent’ or upwards, with responses not 
varying significantly between stakeholder groups. 

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Figure 62. 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 reports. 892 Most national authorities believed the 
Regulation  has  had  a  positive  impact  in  this  regard. 893  About  a  third  of  respondents 
(19/65)  across  stakeholder  groups  believed  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) believing the Regulation had a rather positive impact, while another third (9 out of 
30) felt it had not significantly improved timeliness or had only marginally done so. Two 
from the latter group elaborated 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 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’.894,  

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  interviewed  stakeholders  remarked  that  the  introduction  of  the  Governance 
Regulation and accompanying plans and reports had noticeably improved the availability 
of  information  in  their  Member  State. 895  Several  pointed  out  the  differing  levels  of 
information and completeness of reports between Member States, however, highlighting 
that certain reports do not contain the expected data.896 Several interviewed national 
authorities  emphasised  issues  with  timeliness  and  timeframes  of  reporting  and 

892 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”. 
893 Three quarters (23/30) believed the Regulation had contributed to greater accessibility at least ‘to some 
extent’.  
894  Six  out  of  15  industry  stakeholders  and  eight  out  of  19  third-sector  respondents  chose  one  of  these 
answers. 
895 Interviews with two national authorities, one research organisation, seven civil society organisations. 
896 Interviews with three EU bodies, one industry association, three research organisations, three civil society 
organisations. 

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updates.897 Some also remarked that certain data required by the European Commission 
were unavailable in their Member State. 898 In contrast, several interviewed stakeholders 
recognised improvements since the first NECPs were published.899 

Usefulness of national plans and reports 

The  surveyed  national  authorities  indicated  that  information  contained  in  NECPs, 
national LTSs and Member States’ progress reports had been used for decision-making 
at  a  national  level.900  The  opinions  among  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 
priority.901 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".902 

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 delay.903 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 
information.904 

Interviews with national authorities revealed that while some Member States viewed the 
NECPs and LTSs as strategic and policy-setting documents, others tended to perceived 
them as a compendium or existing data and current or planned measures, with varying 
levels of usefulness depending on whether similar documents were already established 
nationally.905  Several  third-sector  stakeholders  highlighted  shortcomings  in  internal 
coherence and usefulness resulting from the fact that the first NECPs were submitted 
before LTSs, meaning that they lack the long-term political vision and impetus which 
would govern policy and goal attainment.906 

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 NECPs.907  

Some respondents to the Call for Evidence found the design of NECPs to be ineffective 
or  insufficient  to  address  the  gap  between  measures  and  objectives.908  Specifically, 
according  to  eight  respondents,  the  NECP  template  provided  in  Annex  I  of  the 

897 Interviews with three national authorities. 
898 Interviews with two national authorities. 
899 Interviews with one research organisation, two civil society organisations. 
900 More than two thirds (19/27) answered with ‘To some extent’ and upwards. 
901 NGOs (1); Environmental organisation (1); Academic (1) 
902 Public authority (1) 
903 NGOs (6); Environmental organisations (1); Academic (1) 
904 Public authority (1) 
905 Interviews with five national authorities, two civil society organisations. 
906 Interviews with one individual expert, two research organisations, three civil society organisations. 
907 NGOs (2); Business Associations (2); Academic (1); Other (1);  
908 NGOs (1); Business associations (1); Environmental organisations (2) 

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Governance Regulation no longer reflects the latest scientific progress or developments 
in EU climate and energy policies.909  

Some  interviewed  stakeholders  agreed  that  the  Governance  Regulation  has  helped 
integrate and streamline previously scattered obligations.910 On the other hand, several 
interviewees  argued  that  the  Governance  Regulation  had  also  made  their  Member 
State’s  planning  and  reporting  processes  more  complex.911  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,  efficiently  (as  they  often  have  to  rely  on  consultancies  to 
complete tasks) and on time.912 Changing political priorities was also highlighted as a 
barrier for medium and long-term consistency.913 

Several  interviewed  national  authorities  mentioned  that  the  guidance  shared  by  the 
European Commission had proved relevant and useful.914 

Effective enforcement 

Surveyed  stakeholders  held  differing  views  on  whether  the  Regulation’s  enforcement 
mechanisms (for addressing 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, whilst 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 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 targets.915 They highlighted that the current rules are insufficient to 
ensure  that  Member  States  comply  with  their  targets.  Specifically,  stakeholders 
considered  that  the  current  delivery  gap  mechanism  (Article  32)  is  not  functioning 
effectively, and that there is a need for quicker intervention and greater transparency 
in  discussions  between  the  European  Commission  and  Member  States  on  measures 
being taken. 

Several interviewed stakeholders underlined that Member States’ compliance with the 
Regulation’s obligations was sometimes limited. However, limited compliance was not 
always  found  to  pertain  to  the  Regulation  itself,  but  rather  to  be  linked  to  political 
considerations and the need to acquire buy-in from Member States in light of growing 
obligations and administrative burden. 916 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-compliance.917 

909 NGOs (3); Business associations (4); Environmental organisation (1) 
910  Interview  with  one  EU  body,  three  national  authorities,  two  research  organisations,  two  civil  society 
organisations. 
911 Interview with two national authorities. 
912 Interview with one national authority, one individual expert, two research organisations, one civil society 
organisation. 
913 Interview with one national authority, two research organisations. 
914 Interviews with three national authorities. 
915 NGOs (10); Business associations (1); Environmental organisations (3); Academic (2) 
916  Interviews  with  two  EU  bodies,  one  national  authority,  one  research  organisation,  two  civil  society 
organisations. 
917 Interview with one individual expert, one research organisation, seven civil society organisations. 

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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 enhancing the predictability 
and certainty for investors, if at all.918 

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). Thus, 
by  providing  regulatory  certainty,  the  Governance  Regulation  may  have  helped 
stimulate investment and ensure market stability. 

Although  several  interviewed  stakeholders  thought  that  the  Regulation’s  plans  and 
reports should contribute to greater predictability and certainty for public and private 
investors,919 they found it generally unclear whether this had materialised into enhanced 
levels of investment. One interviewed national authority highlighted that the timeline of 
NECPs  and  of  their  update  was  not  set  up  to  inform  the  EU  budget,  with  no  way  of 
reprogramming  funds  before  2027  (e.g.,  structural  funds,  Just  Transition  funds  or 
Common  Agricultural  Policy)  to  support  the  implementation  of  the  NECPs.  Four 
interviewed  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 investment.920 

Regional cooperation 

A majority of surveyed national authorities thought that the Governance Regulation has 
led Member States to increase or take more advantage of their cooperation with each 
other.921  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  Regulation,922  although 
one indicated that such cooperation would probably have taken place even without the 
Governance Regulation. One interviewed EU official considered that regional cooperation 
remains underutilised at an 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  stakeholders.923  They  also 
tended  to  think  that  their  country  had  involved  the  public  and  taken  due  account  of 

918 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’. 
919 Interviews with two EU bodies, three national authorities, two civil society organisations. 
920 Interview with three research organisations, seven civil society organisations. 
921 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’. 
922 Interview with four national authorities. 
923 A majority (16/24) considered this was done ‘to a large extent’ or ‘to a very large extent’. 

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public feedback when drafting and updating national plans, at least to some extent. 924 
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 progress,925 and half also thought that Member States had 
not provided the public with effective and timely opportunities to comment and engage 
in the developments of NECPs and LTSs.926  

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 
NECPs.927 They indicated that public participation had varied significantly across Member 
States and had frequently not been very meaningful. Some respondents also mentioned 
that Article 11 (multilevel 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  policy. 928 
They  found  that  the  establishment  and  regular  meetings  of  multilevel  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  interviewed  stakeholders  underlined  that  multilevel  dialogues  and  public 
consultations  had  been  insufficiently  conducted  by  Member  States.929  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  action. 930 
Nevertheless,  some  third-sector  interviewees  found  that,  when  conducted,  multilevel 
dialogues and public consultations had not always been substantial or influential enough 
to inform planning and reporting.931 One interviewed civil society organisations indicated 
that they had conducted their own research on the application of Article 11 and found 
that  the  language  in  the  Regulation  lacked  clarity  and  that  implementation  was  not 
sufficiently  transparent.  Significant  variations  between  Member  States  in  the 
implementation of Articles 10 and 11 were highlighted by interviewees. Some national 
authorities argued that such consultations were complex and often suffered from a lack 
of  time  to  prepare  and  conduct  them  meaningfully.932  Three  interviewed  national 
authorities  remarked  on  the  positive  results  that  multilevel  dialogue  and  /  or  public 
consultations  had  reaped  in  their  Member  States.  However,  two  national  authorities 
noted that similar dialogues and consultations were already in place before the adoption 
of the Governance Regulation. 

Participants responding to the live poll during the stakeholder event generally agreed 
(35/58) that a combination of both 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. 

924 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’. 
925 Most (9/17) said this had been done ‘only to a small extent’, if ‘not at all’. 
926 Half (7/14) said Member States did so ‘only to a small extent’ or ‘not at all’. 
927 NGOs (8); Business associations (1); Environmental organisations (3); Academic (1)  
928 NGOs (8); Business associations (1); Environmental organisations (1); Other (1) 
929 Interview with one EU body, two industry organisations, six civil society organisations. 
930 Interview with one individual expert, two research organisations, two civil society organisations. 
931 Interview with one research organisation, five civil society organisations. 
932 Interviews with three national authorities. 

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A6.3.3. 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 thought that: 

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

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 
requirements.933  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, which had increased 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 addressing the need 
for  granular  information  in  national  plans  and  reports  on  the  one  hand  and  keeping 
administrative burden proportional on the other. 

Most interviewed national authorities 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 
State.934 

Cost items 

National  authorities  generally  observed  that  costs  had  risen  for  most  of  the  items 
presented  to  them,  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  led  to  any  cost  savings  for  their 
authority and only a small minority of survey respondents identified any cost saving at 
all.  The  following  elements  had  the  highest  number  of  respondents  indicating  an 
increase in costs associated with implementing the Regulation: 

Human  resources  necessary  to  fulfil  obligations  (according  to  16  out  of  18 
national authorities providing an answer on this item, with 16 considering that 
this item had led to cost increases and 2 considering that associated costs had 
remained the same).Overall costs of preparing and submitting reports (14 out of 
17  considering  that  this  item  had  led  to  cost  increases,  with  a  further  two 
respondents considering that associated costs had remained the same and one 
believing it had led to a decrease in costs). 

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

Running costs for coordination and data compilation (13 out of 16  considering 
that  this  item  had  led  to  cost  increases,  with  a  further  two  respondents 
considering  that  associated  costs  had  remained  the  same  and  one  believing  it 
had led to a decrease in costs). 

933 NGOs (1); Public authority (2) 
934 Interviews with four national authorities. 

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External  costs  such  as  consulting  and  support  (according  to  13  out  of  16 
respondents, with a further three considering 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 them.935 

Efficiencies and cost savings 

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

Through  higher  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 with that statement). 

Through higher coordination of different competent authorities (according to 14 
out of 21 respondents, although a further three respondents disagreed with that 
statement). 

Through having better established processes, policies and procedures (according 
to  13  out  of  21  respondents,  with  another  three  disagreeing  with  that 
statement). 

Through improved quality and timeliness of information produced (according to 
12 out of 21 respondents, while a further five national authorities disagreed with 
that statement). 

Reporting via the EU electronic platform(s) 

Overall, surveyed national authorities had mixed views on the impacts that electronic 
reporting  to  Reportnet  and  ReportENER  had  on  their  services’  costs,  time  and 
administrative burden. Although more respondents agreed than not (12/28) that the EU 
electronic reporting 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 introduce or maintain a similar reporting 
platform at a national level. More often than not (12/28), surveyed national authorities 
found that submitting information via Reportnet had led to more costly, complex and 
time-consuming reporting in their Member State than what would otherwise have been 
the case. 

Timing of planning and reporting obligations 

Surveyed  national  authorities  had  mixed  views  on  whether  the  timing  of  obligations 
under  the  Governance  Regulation  are  internally  consistent  and  reasonable936,  and 
whether  they  are  consistent  with  the  timing  of  national  obligations937  and  other  EU 
obligations.938 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. 

935 Interviews with two national authorities, one individual expert. 
936 Eleven out of 25 respondents disagreed (6/25) or strongly disagreed (5/25) with that statement, against 
nine who agreed. 
937 Twelve out of 26 respondents disagreed (8/26) or strongly disagreed (4) with that statement, against ten 
who agreed. 
938 Ten out of 26 respondents agreed with that statement, against nine who disagreed. 

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Two public authorities that responded to the Call for Evidence argued that the reporting 
platforms used for Member States’ submissions were not efficient.939 One stakeholder 
explained that having to use two different platforms was suboptimal and hindered the 
efficient transfer  of the necessary information. Another  stakeholder 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, or easily accessible or readable 
once  uploaded.940  Several  stakeholders  were  confused  about  the  existence  of  two 
different  e-reporting  platforms.941  Third-sector  interviewees  tended  to  have  more 
positive views and experiences of these platforms and their usefulness, as well as of the 
data  they  include.942  Some  still  highlighted  issues  with  user-friendliness  and 
readability. 943  

A6.3.4. Coherence 

Internal coherence 

Surveyed  national  authorities  generally  thought  that  the  obligations  contained  within 
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  who  believed  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 its 
Article  17(3)  on  greenhouse  policies  and  measures  (three    surveyed  national 
authorities); 

overlaps in the elements included in Sections 2, 3, 4 and 5 under each dimension 
of the NECP template, as included in Annex I of 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 Regulation.944 Some argued 
that  the  sequencing  of  NECPs  and  LTSs  was  not  coherent,  with  the  first  LTSs  being 
submitted after NECPs, while the former should inform the latter.945 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 NECPs.946  

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 
contravened the internal coherence of the Governance Regulation.947 This was similarly 

939 Public authority (2) 
940 Interviews with four national authorities. 
941 Interviews with three national authorities, one research organisation. 
942 Interviews with one individual expert, one research organisation, three civil society organisations. 
943 Interviews with two research organisations, three civil society organisations. 
944 NGOs (5); Environmental organisations (2); Academic (1) 
945 NGOs (1); Academic (1) 
946 NGOs (1) 
947 Interviews with two research organisations, four civil society organisations. 

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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, with alignment between the two documents 
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 Package 948 and the European Climate Law.949 Views were slightly more divided 
on  EU  initiatives  with  climate  and  energy  implications,  such  as  REPower  EU,  the 
Recovery  and  Resilience  Facility,  and  the  European  Semester.950  Most  national 
authorities  thought  the  Regulation  is  coherent  with  the  United  Nations  Framework 
Agreement  on  Climate  Change  (UNFCCC)  and  the  Paris  Agreement951,  with  only  one 
respondent  disagreeing.  Half  the  responding  national  authorities  (12/23)  thought  the 
Governance Regulation is at least somewhat coherent with the Aarhus Convention 952, 
although a large minority said 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 relevant 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 other. 953 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  inform  the  planning  processes 
under the Governance Regulation – and vice versa.954  

Respondents  to  the  Call  for  Evidence  argued  that  the  Governance  Regulation  lacks 
coherence with newer pieces of EU legislation. They mentioned in particular the newly-
adopted EU targets for renewable energy and energy efficiency. 955  

Several  interviewed  stakeholders  believed  the  Governance  Regulation  needs  to  be 
updated to be coherent with newly adopted EU legislation.956 On the other hand, some 
interviewees  believed  the  Regulation  remains  coherent  with  the  overarching  EU 
framework  and  should  not  seek  to  be  too  prescriptive,  lest  it  falls  behind  future 

948  Twenty  out  of  24  national  authorities  and  nine  out  of  ten  third-sector  respondents  answered  ‘To  some 
extent’ or upwards. 
949 Twenty out of 23 national authorities and seven out of ten third-sector respondents answered ‘To some 
extent’ or upwards. 
950 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). 
951 Thirteen out of 24 responded ‘To a large extent’ and upwards, as well as seven responding with ‘To some 
extent’. 
952 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 
953 NGOs (1) 
954 Academic (1) 
955 NGOs (2); Business associations (2); Public authority (1); Company/Business (1); Other (1). 
956 Interviews with one EU body, two research organisations, five civil society organisations. 

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initiatives.957 Some timing inconsistencies between other EU or international obligations 
were identified as limiting coherence and creating added burden.958 

As  regards  coherence  with  international  processes,  six  respondents  to  the  Call  for 
Evidence indicated that the alignment between the 5-year common timeframe of the EU 
climate policy cycle and the UNFCCC should be strengthened, as foreseen by Article 4(7) 
of the European Climate Law. 959  

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 pointed to the same 
issue in the context of  greenhouse gas projections and adaptation reporting. Another 
national authority pointed to 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 administrative burden.  

A6.3.5. EU added value 

Scenario without the Regulation 

A slight majority of surveyed national authorities (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 
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  information  availability,  accessibility  and  comparability  at  EU  level  that  would  not 
have been achieved by Member States on their own.960 Several interviewed stakeholders 
thought that the Governance Regulation had improved consistency of national energy 
and  climate  strategies  across  EU  Member  States, 961  and  enhanced  streamlining  and 
coordination of national planning and reporting processes. 962 On the other hand, some 
interviewees  noted  that  there  remains  scope  to  improve  the  consistency  of  adopted 
policies, and the comparability of reports and data.963 All interviewees, even those from 
Member  States  with  stronger  pre-existing  frameworks,  thought  the  Governance 
Regulation provides added value. 

Harmonisation and predictability of national policies 

Survey  respondents  had  mixed  views  about  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) 

957 Interviews with one EU body, one national authority. 
958 Interviews with one EU body, two national authorities, two civil society organisations. 
959 NGOs (3); Environmental organisations (2); Public authority (1)  
960  Interviews  with  two  EU  bodies,  two  national  authorities,  one  research  organisation,  four  civil  society 
organisations. 
961 Interview with one EU body, one national authority, two civil society organisations. 
962 Interviews with one EU body, one national authority, two civil society organisations 
963  Interviews  with  two  EU  bodies,  one  national  authority,  one  research  organisation,  three  civil  society 
organisations. 

. 

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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  with  this  assertion.  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 being made more transparent and predictable. 964 
Industry  respondents  were  evenly  split  between  those  that  agreed  and  those  that 
disagreed with this statement.  

Interviewed stakeholders had mixed views about whether the  Governance Regulation 
has enhanced transparency and predictability.965 Some believed that the Regulation has 
only had a limited effect and that much remains to be done to improve in this regard. 966 
Overall, interviewees tended to have reservations, show uncertainty or scepticism when 
answering this question, 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  to  digest  the 
information.967 

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 actors 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) thought 
the Governance Regulation lacks adequate 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 actors in their Member State are 
able to access justice and hold governments accountable for their obligations under the 
Governance Regulation.968 

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  ensured.969  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. 

964  Thirteen  out  of  25  national  authorities  agreed  or  strongly  agreed,  and  seven  out  of  14  third-sector 
respondents agreed or strongly agreed. 
965  Interviews  with  one  EU  body,  two  national  authorities,  one  research  organisation,  four  civil  society 
organisations. 
966 Interviews with one national authority, one industry organisation, two civil society organisations. 
967 Interviews with two industry organisations, one research organisation, two civil society organisations. 
968 Out of 17 respondents, six disagreed and three agreed. The majority of respondents did not choose either 
option or said they did not know. 
969 Interview with two research organisations and four civil society organisations. 

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ANNEX 7. CLASSIFICATION OF OBLIGATIONS FROM ENERGY AND 
CLIMATE ACQUIS INCLUDED IN THE GOVERNANCE REGULATION 
(BASELINE) 

According  to  the  SWD  (Annex  6),  when  referring  to  the  energy  legislative 
framework  relevant  to  the  Regulation    ‘Integrate  means  the  obligation  is 
integrated 
integrated 
in  National  Plans,  Progress  Reports  and 
Commission monitoring; Keep  separate means  the  obligation  remains 
an  entirely  separate  obligation  in  sectorial  legislation  (with  possible 
amendments);  or  Keep  separate  and  reflect  means  the  obligation 
remains  a  separate  obligation  in  sectorial  legislation,  which  will 
however  be  reflected  in  the  National  Plans  Progress  Reports  and 
integrated Commission monitoring; Repeal means the obligation is fully 
repealed from current sectorial legislation and thus removed from the 
EU energy and climate acquis’.970  
According  to  the  SWD  (Annex  7),  when  referring  to  the  climate  legislative  framework 
relevant to the Regulation  ‘Integrate means the obligation is integrated in National Plans, 
Progress Reports and integrated Commission monitoring (and at the same time being 
amended in or repealed from current sectorial legislation); Linked means the obligation 
is remaining a separate obligation from National Plans, Progress Reports and integrated 
Commission monitoring but, given its relation to obligations to be integrated in National 
Plans,  Progress  Reports  and  integrated  Commission  monitoring,  linked  to  those 
obligations and to follow the legal destination of those obligations; Repeal means the 
obligation is fully repealed from current sectorial legislation and thus removed from the 
EU energy and climate acquis’.971 

The  identification  of  the  baseline  for  the  evaluation  of  the  Governance  Regulation 
followed the same approach, and used the obligations listed in the SWD as the starting 
point of the exercise. The analysis updated the provisions as  relevant (since  some  of 
them have been amended or repealed since) and made an effort to identify the reporting 
obligations  in  the  Governance  Regulation  and  the  dimensions  of  the  Energy  Union  to 
which they correspond. In a few instances, this correspondence was not very clear, and 
comments  have  been  left  in  the  table,  signalling  where  input  from  DG  ENER/CLIMA 
would be needed. 

970 COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal 
for a Regulation of the European Parliament and the Council on the Governance of the Energy Union, amending 
Directive 94/22/EC, Directive 98/70/EC, Directive 2009/31/EC, Regulation (EC) No 663/2009, Regulation (EC) 
No  715/2009,  Directive  2009/73/EC,  Council  Directive  2009/119/EC,  Directive  2010/31/EU,  Directive 
2012/27/EU, Directive 2013/30/EU and Council Directive (EU) 2015/652 and repealing Regulation (EU) No 
525/2013 - SWD/2016/0394 final - 2016/0375 (COD),  available at:  

https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:52016SC0394  
971 Ibid.  

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Table 69.  Classification of obligations from energy and climate acquis included in the Governance Regulation (baseline) 

Name 
obligation  

of 

Legal 
basis  

Art.   Description 
obligation  

of 

Type 
of 
obligation  

Frequen
cy  

Entity 
targeted 
by 
the 
obligatio
n 

Manner 
of 
inclusio
n 

Dimension 
the 
of 
Energy 
Union 

Correspond
ing 
obligation 
in 
Governanc
e 
Regulation 

the 

Energy acquis 

Connecting 
Europe  Facility 
Regulation 

22 

Regulation 
(EU)  No 
1316/201
3  

Report  on  progress 
and 
investments 
made in projects of 
common interest  

Reporting  

Annual  

MS 

Electricity 
Directive  

4 

Directive 
2009/72/E
C  

Electricity 
Directive  

22 

Directive 
2009/72/E
C  

Monitoring 
of 
security  of  supply 
with 
MS, 
by 
possibility 
to 
delegate to NRA  

Submit  a  national 
ten-year  network 
development  plan 
based  on  existing 
and forecast supply 
and 
demand, 
containing  efficient 

Reporting  

MS  

Every  2 
years,  by 
31 July  

Planning  

Annual  

Transmis
sion 
System 
Operator
s (TSOs) 

Kept 
separate, 
and 
reflected
972  

Kept 
separate, 
and 
reflected
973  

Kept 
separate
974   

Art. 23 

Art. 23 

Internal 
energy 
market 

Internal 
energy 
market 

Not  included 
in 
the 
Governance 
regulation 

Internal 
energy 
market 

972 Instrument repealed by Regulation (EU) 2021/1153 establishing the Connecting Europe Facility and repealing Regulations (EU)1316/2013 and (EU) 283/2014    
973 Instrument repealed by Directive (EU) 2019/944 on common rules for the internal market for electricity and amending Directive 2012/27/EU (recast) 
974 Instrument repealed by Directive (EU) 2019/944 on common rules for the internal market for electricity and amending Directive 2012/27/EU (recast)   

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Name 
obligation  

of 

Legal 
basis  

Art.   Description 
obligation  

of 

Type 
of 
obligation  

Frequen
cy  

Entity 
targeted 
by 
the 
obligatio
n 

Manner 
of 
inclusio
n 

Dimension 
of 
the 
Energy 
Union 

Correspond
ing 
obligation 
in 
Governanc
e 
Regulation 

the 

Electricity 
Directive  

47  

Directive 
2009/72/E
C  

Energy 
Efficiency 
Directive 

3 

Directive 
2012/27/E
U  

measures  in  order 
to  guarantee  the 
the 
adequacy  of 
the 
system  and 
security of supply  

Overall 
progress 
report  on  internal 
market 
of 
electricity;  should 
MS 
include 
measures 
for 
improving 
competition 
recommendations  

+/- 

Member State shall 
indicative 
set  an 
national 
energy 
efficiency target  

Monitoring   Annual  

EC 

Art. 35 

Internal 
energy 
market 

Kept 
separate, 
and 
reflected
975  

Planning  

First 
when 
transposi
ng 
the 
Directive, 
with 
possible 
revision 
every  3 

MS  

Integrate
d 

Energy 
efficiency 

Article 
4(b)(1) 
the NECP) 

(in 

(+  Article  6 
about 
related 
consideratio
ns) 

975 Instrument repealed by Directive (EU) 2019/944 on common rules for the internal market for electricity and amending Directive 2012/27/EU (recast) 

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Name 
obligation  

of 

Legal 
basis  

Art.   Description 
obligation  

of 

Type 
of 
obligation  

Frequen
cy  

Entity 
targeted 
by 
the 
obligatio
n 

Manner 
of 
inclusio
n 

Dimension 
of 
the 
Energy 
Union 

Correspond
ing 
obligation 
in 
Governanc
e 
Regulation 

the 

Energy 
Efficiency 
Directive 

Directive 
2012/27/E
U  

Energy 
Efficiency 
Directive 

Directive 
2012/27/E
U  

24(2
), 
Anne
x 
XIV
976 
Part
2 

4 
(the
n 
Articl
e  2a 
of 
the 

years  (in 
NEEAPs) 

National 
Efficiency 
Plans (NEEAPs) 

Energy 
Action 

Every  3 
years  

MS 

Integrate
d 

Long-term strategy 
for 
mobilising 
investment  in  the 
renovation  of  the 

Planning 
and 
reporting 

Every  3 
years  

MS  

Integrate
d 

Energy 
efficiency 

Energy 
efficiency 

(cf. 

NECP 
Article 
+ 
3(2)(c) 
Annex 
I, 
sections  2.2 
and  3.2  of 
the 
NECP 
template)977 

In  NECP,  cf. 
Article 
4(b)(3), 
Annex 
(sections 
2.2(ii) 
and 
3.2(ii) of the 

I 

976 The Governance Regulation deleted Annex XIV of the EED. This can be considered as an example of ways the Governance Regulation ‘takes over’ reporting obligations 
previously listed in Annex XIV EED.  

977 It would be possible to compare the indicative template for the NEEAPs (cf. part 2 of Annex XIV of the EED2012) and the sections on energy efficiency in the mandatory 
template for the NECP to identify a more specific correspondence.  

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Name 
obligation  

of 

Legal 
basis  

Art.   Description 
obligation  

of 

Type 
of 
obligation  

Frequen
cy  

EPB
D) 

national 
stock 978 

building 

Entity 
targeted 
by 
the 
obligatio
n 

Manner 
of 
inclusio
n 

Dimension 
of 
the 
Energy 
Union 

Correspond
ing 
obligation 
in 
Governanc
e 
Regulation 

the 

NECP 
template) 

In NECPR, cf. 
21 
Article 
(points 
(a)(2) 
(b)(4)) 

and 

Energy 
Efficiency 
Directive 

5 

Directive 
2012/27/E
U  

Planning 

exemplary  role  of 
buildings 
public 
and 
(target 
for 
approach 
central government 
buildings) 

by 

First 
notificati
on 
Decembe
r  2013,  
then 
possible 
updates 

MS 

Integrate
d 

Article 
4(b)(4) 
NECP) 

Energy 
efficiency 

(in 

978 Two separate provisions are in fact relevant in this case 1) The renovation targets and milestones that are indeed included in the NECP, with progress monitored in the 
NECPR and 2) The Long-Term Renovation Strategy itself, which was reported separately until the Governance Regulation. The Governance Regulation includes an amendment 
to Article 2a of the EPBD, to clarify that “each Member State's long-term renovation strategy shall be submitted to the Commission as part of its final integrated national 
energy and climate plan”, with the derogation that the first LTRS related to Art.2a of the EPBD was due by 10 March 2020. Which may have been a way to avoid overloading 
MS at the time they had to submit their first NECP.  

The LTRS will become the BRP (Building Renovation Plans) with the EPBD Recast, that should remain linked to the NECP. But not this year again, as the EPBD recast is not 
yet adopted, postponing the deadline for the first BRP. 

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Name 
obligation  

of 

Legal 
basis  

Art.   Description 
obligation  

of 

Type 
of 
obligation  

Frequen
cy  

Entity 
targeted 
by 
the 
obligatio
n 

Manner 
of 
inclusio
n 

Dimension 
of 
the 
Energy 
Union 

Correspond
ing 
obligation 
in 
Governanc
e 
Regulation 

the 

Energy 
Efficiency 
Directive 

Directive 
2012/27/E
U  

Planning  

7(9), 
and 
Anne
x V 

of 
notification 
energy 
efficiency 
obligation  schemes 
alternative 
and 
measures  reported 
to Article 7(1) 

in  annual 
reports 
and 
NEEAPs 

by 

First 
notificati
on 
Decembe
r  2013, 
then 
possible 
updates 
in  annual 
reports 
and 
NEEAPs  

MS  

Integrate
d 

Energy 
efficiency 

III 
all 

Annex 
(listing 
reporting 
requirement
s)979 

Articles 
3(2)(h)  and 
4(b)(2) 
(in 
NECP)  

Article 
NECPR) 

(in 

Energy 
Efficiency 
Directive 

Directive 
2012/27/E
U  

Anne
x 
VIII 

Comprehensive 
assessment  of  the 
of 
potential 
cogeneration  and 

Planning  

Every  5 
years  

MS   

Kept 
separate, 
and 
reflected 

Not  included 
in 
the 
Governance 

Energy 
efficiency 

979 This is an example where the Governance Regulation brought more clarity about how Member States should notify to the Commission information relevant to the EED 
energy savings obligation (previously Article 7 now Article 8 of the EED).  

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371 

 
 
 
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Name 
obligation  

of 

Legal 
basis  

Art.   Description 
obligation  

of 

Type 
of 
obligation  

Frequen
cy  

Entity 
targeted 
by 
the 
obligatio
n 

Manner 
of 
inclusio
n 

Energy 
Efficiency 
Directive 

Directive 
2012/27/E
U  

district heating and 
cooling 

report 
Progress 
(annual  report  to 
the EED) 

24(1
), 
Anne
x 
XIV
981 

Reporting  

Annual  

MS  

Integrate
d 

Dimension 
of 
the 
Energy 
Union 

Energy 
efficiency 

Correspond
ing 
obligation 
in 
Governanc
e 
Regulation 

the 

Regulation
980 

Article  21(a) 
and  Annex 
IX  (part  2) 
(reporting on 
energy 
efficiency  in 
NECPR)982 

980 This assessment should change, as per. Article 25 of the EED Recast (replacing Article 14 of EED(2012): ‘’As part of its integrated national energy and climate plan 
and  its  updates  pursuant  to  Regulation  (EU)  2018/1999,  each  Member  State  shall  submit  to  the  Commission  a  comprehensive  heating  and  cooling 
assessment’’. The same new article of the EED recast makes the link between the comprehensive assessment for heating and cooling and the assessment of renewable 
energy potentials for heating and cooling (cf. Article 15(7) of Directive (EU) 2018/2001 - Renewable Energy Directive). 

981 Same comment on  Annex XIV (part 2) of the EED applies, as the Governance Regulation deleted Annex XIV of the EED. 

982 There might be some differences in the requirements between both, annual report to the EED and NECPR. Most of the obligation requirements on energy efficiency in the 
NECPR come indeed from the former Annex XIV part 1 of the EED. But it also includes a few details that were previously included in the NEEAPs (or not reported). A comparison 
of part 1 of Annex XIV of the EED with part 2 of Annex IX of the Governance Regulation (and possibly as well with the implementing regulation including the NECPR template) 
could provide better details.  For example, progress with the long-term renovation strategies was previously included in the update of the LTRS, attached to the NEEAP (so 
every three years). Currently, Member States have to report some indicators about their building stock and building renovations in the NECPR (so every 2 years). However, 
most of these data are not mandatory, and the Commission’s assessment confirmed that therefore, only a few Member States  reported the non-mandatory data in their 
NECPR2023. 

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Name 
obligation  

of 

Legal 
basis  

Art.   Description 
obligation  

of 

Type 
of 
obligation  

Frequen
cy  

Entity 
targeted 
by 
the 
obligatio
n 

Manner 
of 
inclusio
n 

Part 
1 

Energy 
Efficiency 
Directive 

Directive 
2012/27/E
U  

24(3
)  

of 
Evaluation 
annual  reports  and 
NEEAPs  

Monitoring   Other  

EC  

Integrate
d 

Dimension 
of 
the 
Energy 
Union 

Energy 
efficiency 

Correspond
ing 
obligation 
in 
Governanc
e 
Regulation 

the 

+  Article  27 
(report 
on 
the 
achievement 
of  the  2020 
targets) 

Article  29(3) 
about 
headline 
target 
(Article 
EED) 

3 

Article 
35(2)(h) 
about 
energy 
savings 
obligation 
(Article 
EED) 

7 

Energy 
Efficiency 
Directive 

Directive 
2012/27/E
U  

24(4
) 

Monitor  impact  of 
the 
implementing 
EED  on  the  ETS 
Directive,  the  RES 
Directive, the EPBD 

Monitoring   Other  

EC  

Repealed  No 

longer 
needed,  due 
the 
to 

Energy 
efficiency 

September, 2024 

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Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

Name 
obligation  

of 

Legal 
basis  

Art.   Description 
obligation  

of 

Type 
of 
obligation  

Frequen
cy  

the 

Directive, 
Effort-sharing 
Decision 
industry 
(carbon 
sectors) 

and 
sectors 
leakage 

Entity 
targeted 
by 
the 
obligatio
n 

Manner 
of 
inclusio
n 

Dimension 
of 
the 
Energy 
Union 

Correspond
ing 
obligation 
in 
Governanc
e 
Regulation 

the 

integrated 
reporting 

Energy 
Efficiency 
Directive 

Directive 
2012/27/E
U  

24(1
1)  

Monitoring 

of 
publication 
reports  referred  to 
in Article 24(1) and 
(2)  

EC  

in 
As 
1 
para 
and 
2 
(annually 
and 
every 
three 
years 
respectiv
ely) 

Energy 
Labelling 
Directive 

Directive 
2010/30/E
U 3983 

3(3)   Enforcement 

Reporting  

activities  and  level 
of compliance  

Every  4 
years  

MS  

Repealed   NECPs 

are 
published  on 
the 
Commission 
website 

Energy 
efficiency 

NECPR  data 
are 
published  on 
ReportNET 

Repealed    Not  included 
in 
the 
Governance 
Regulation  - 
Now  part  of 

Energy 
efficiency 

983 This Directive was repealed by Regulation (EU) 2017/1369, before the adoption of the Governance Regulation. As the 2017, Regulation on energy labelling reads, these 
articles  have  been  replaced  by  Article  8(1)  of  the  2017  regulation  that  refers  to  Art.19  to  Art.26  of  the  Regulation  (EC)  No  765/2008  setting  out  the  requirements  for 
accreditation and market surveillance. (see: http://data.europa.eu/eli/reg/2008/765/oj). Therefore, this reporting is now done as part of the general reporting on market 
surveillance (not linked to the Governance Regulation).  

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Name 
obligation  

of 

Legal 
basis  

Art.   Description 
obligation  

of 

Type 
of 
obligation  

Frequen
cy  

Entity 
targeted 
by 
the 
obligatio
n 

Manner 
of 
inclusio
n 

Dimension 
of 
the 
Energy 
Union 

Correspond
ing 
obligation 
in 
Governanc
e 
Regulation 

the 

Regulation 
(EC) 
No 
765/2008 on 
market 
surveillance 

Energy 
Labelling 
Directive 

Directive 
2010/30/E
U 3 

3(4)   Synthetic  report  of 
years 

4 
MS 
reporting  

Monitoring   Every  4 

EC 

years   

Repealed  Not  included 
the 
in 
Governance 
Regulation  - 
Now  part  of 
Regulation 
No 
(EC) 
765/2008 on 
market 
surveillance 

Energy 
Performance 
of  Buildings 
Directive 

Directive 
2010/31/E
U   

input 
5(2)  Report  all 
data 
and 
assumptions  used 
cost-optimal 
for 
calculations 
and 
their results 

Reporting  

Every  5 
years  

MS  

Integrate
d 

I 

of 
NECP 

Annex 
(section 
4(3)(iv) 
the 
template; 
however, 
cost-optimal 
levels only in 
the 
NECP 
(details  are 

Energy 
efficiency 

Energy 
efficiency 

September, 2024 

375 

 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

Name 
obligation  

of 

Legal 
basis  

Art.   Description 
obligation  

of 

Type 
of 
obligation  

Frequen
cy  

Entity 
targeted 
by 
the 
obligatio
n 

Manner 
of 
inclusio
n 

Energy 
Performance 
of  Buildings 
Directive 

Directive 
2010/31/E
U   

9.5   Report  on  progress 
of  MS in increasing 
the 
of 
number 
nearly  zero  energy 
buildings 

Monitoring   Every  3 

EC  

years  

Integrate
d 

Correspond
ing 
obligation 
in 
Governanc
e 
Regulation 

the 

provided 
separately)
984  

Article 
35(2)(j) 
(every 
years)985 

4 

Dimension 
of 
the 
Energy 
Union 

Energy 
efficiency 

Energy 
Performance 
of  Buildings 
Directive 

Directive 
2010/31/E
U   

10.2   List 

of 

existing 
and 

measures 
instruments, 
including financial  

Reporting    Every  3 

MS 

years  

Integrate
d 

NECP: Annex 
I 
(section 
3.2) 

Energy 
efficiency 

NECPR: 
Article 
21(b)(1), 

984 Frequency of reporting for the detailed report is still 5 years, not modified by the Governance Regulation. By coincidence, it happens the same year as the drafts of the 
NECP cycle. First ones were reported in 2013, then 2018 and 2023. The first report was supposed to be due on 30 June 2012, but apparently the deadline was adapted. The 
Governance Regulation does not include explicitly this reporting obligation (only the need for Member States to report the values of cost-optimal levels in their NECP or NECP 
updates).  Member  States  report  on  cost-optimality  are  available  from  the  Commission’s  website,  (at:  https://circabc.europa.eu/ui/group/092d1141-bdbc-4dbe-9740-
aa72b045e8b3/library/30a6e0cd-055a-4623-95ab-e529c2a1b1be?p=1&n=10&sort=modified_DESC) 

985 The change frequency of the reporting obligation from 3 to 4 years was an amendment to the EPBD included in the Governance Regulation, possibly probably to align with 
the frequency of NECPRs, where Member States are required to report about nZEB every two years; therefore an assessment by EC every three years would have create a 
misalignment) 

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Name 
obligation  

of 

Legal 
basis  

Art.   Description 
obligation  

of 

Type 
of 
obligation  

Frequen
cy  

Entity 
targeted 
by 
the 
obligatio
n 

Manner 
of 
inclusio
n 

Dimension 
of 
the 
Energy 
Union 

Correspond
ing 
obligation 
in 
Governanc
e 
Regulation 

the 

and  Annex 
IX  (part  2, 
point (a)) 986 

Energy 
Performance 
of  Buildings 
Directive 

Directive 
2010/31/E
U   

10.3  Examination 

Monitoring   Not 

EC  

specified  

Integrate
d 

Energy 
efficiency 

of 

Part 
Commission’
s 
assessment 
of 
(Art.13(b)) 
and/or of the 
NECPR 
(Art.29)987 

NECP 

Energy 
Performance 

Directive 
2010/31/E
U   

14(3
) and 

Reporting 

? 

MS 

Integrate
d 

NECP (Article 
3, 
and 
reference  to 
Governance 

Energy 
Efficiency 

986 These details were to be included in the NEEAPs before. They are not listed in the Articles of the Governance Regulation. However, they likely correspond to the following 
point  in Annex  I of  the  NECP  template,  at  the beginning  of section  3.2:  “Planned  policies,  measures  and programmes  to  achieve  the  indicative  national  energy  efficiency 
contributions for 2030 as well as other objectives referred to in point 2.2, including planned measures and instruments (also of a financial nature) to promote the energy 
performance of buildings’’.  Another  other possible link would be with this point required in the NECPR (see Annex IX Part 2): “(a) major legislative and non-legislative policies, 
measures, financing measures and programmes implemented in year X-2 and X-1 (with X as the year when the report is due) to achieve their objectives referred to in point 
(b) of Article 4 which promote energy service markets, improve the energy performance of buildings”  

987 See previous comment. The link with the Governance Regulation would be the Commission’s assessment of NECP and NECPR. 

September, 2024 

377 

(monitoring)  of  the 
effectiveness of the 
and 
measures 
instruments, 
including  financial, 
MS 
listed 
pursuant 
to 
Art.10.2 

by 

on 

Report 
impacts 
alternative 
approach 

the 
of 

to 

 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

Name 
obligation  

of 

Legal 
basis  

Art.   Description 
obligation  

of 

Type 
of 
obligation  

Frequen
cy  

Entity 
targeted 
by 
the 
obligatio
n 

Manner 
of 
inclusio
n 

Dimension 
of 
the 
Energy 
Union 

Correspond
ing 
obligation 
in 
Governanc
e 
Regulation 

the 

Regulation 
and 
NECP 
added  in  the 
EPBD) 

Monitoring   Annual  

EC  

Repealed  Article 

28 
has 
been 
deleted - not 
in 
the 
Governance 
Regulation 

Research, 
innovation, 
competitive
ness 

of  Buildings 
Directive 

Financial 
Assistance  in 
the  Field  of 
Energy 
Regulation 

Regulation 
No 
663/2009, 
as 
amended 
by 
Regulation 
1233/201
0 

15(3
) 

28 

mandatory 
of 
inspection 
heating 
systems 
(Art.14)  and  air 
conditioning 
systems (Art.15) 

on 
Report 
implementation  of 
financial  assistance 
to  projects  in  the 
field of energy 

Gas Directive   Directive 

5 

2009/73/E
C  

Gas Directive   Directive 

22 

2009/73/E
C  

Reporting  

MS  

Annual, 
by 
July 

31 

Planning  

Annual  

TSOs 

of 
Monitoring 
security 
of  gas 
supply by MS, with 
to 
possibility 
delegate to NRA  

Submit  a  national 
ten-year  network 
development  plan 
based  on  existing 

Repealed   Article  5  has 
been deleted 
-  not  in  the 
Governance 
Regulation 

Internal 
Energy 
Market 

Art. 23  

Kept 
separate, 
and 
reflected  

Internal 
Energy 
Market 

September, 2024 

378 

 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

Name 
obligation  

of 

Legal 
basis  

Art.   Description 
obligation  

of 

Type 
of 
obligation  

Frequen
cy  

Entity 
targeted 
by 
the 
obligatio
n 

Manner 
of 
inclusio
n 

Dimension 
of 
the 
Energy 
Union 

Correspond
ing 
obligation 
in 
Governanc
e 
Regulation 

the 

Gas Directive   Directive 

52 

2009/73/E
C  

and forecast supply 
and 
demand, 
containing  efficient 
measures  in  order 
to  guarantee  the 
the 
adequacy  of 
system  and 
the 
security of supply 

Overall 
progress 
report  on  internal 
market 
of  gas; 
should  include  MS 
measures 
for 
improving 
competition 
recommendations 

+/- 

Hydrocarbons 
Directive  

Directive 
94/22/EC  

8(2)  Report 

on 

the 
conditions 
for 
granting  and  using 
authorization 
for 
prospection, 
the 
and 
exploration 
production 
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379 

 
 
 
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September, 2024 

380 

 
 
 
 
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September, 2024 

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Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

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September, 2024 

382 

 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

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obligation  

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Art.   Description 
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Type 
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(recast)   

994 Instrument repealed by Regulation (EU) 2019/943 of the European Parliament and of the Council of 5 June 2019 on the internal market for electricity (recast)   

September, 2024 

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Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

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Type 
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a 
European 
generation 
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September, 2024 

384 

 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

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basis  

Art.   Description 
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Type 
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September, 2024 

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Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

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security 

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September, 2024 

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999 Instrument repealed by Directive (EU) 2018/2001 , and changed in November 2023  
1000 Instrument repealed by Directive (EU) 2018/2001 , and changed in November 2023  

September, 2024 

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Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

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obligation  

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Legal 
basis  

Art.   Description 
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Type 
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1001 

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Regulation 

Internal 
energy 
market 

1001 Instrument repealed by Regulation (EU) 2019/941 of the European Parliament and of the Council of 5 June 2019 on risk preparedness in the electricity sector  

September, 2024 

388 

 
 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

Name 
obligation  

of 

Legal 
basis  

Art.   Description 
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of 

Type 
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obligation  

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1002 

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the 
Governance 
Regulation 

Internal 
energy 
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Energy 
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1002 Instrument repealed by Regulation (EU) 2019/941 of the European Parliament and of the Council of 5 June 2019 on risk preparedness in the electricity sector.  
1003 Instrument repealed by Regulation (EU) 2017/1938 
1004 Instrument repealed by Regulation (EU) 2017/1938 

September, 2024 

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Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

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1008  

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1006 Instrument repealed by Regulation (EU) 2016/1952 
1007 Instrument repealed by Regulation (EU) 2016/1952 
1008 Instrument repealed by Regulation (EU) 2016/1952 

September, 2024 

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Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

Name 
obligation  

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Art.   Description 
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Monitoring 
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4 

Regulation 
(EU)  No 
525/2013 

Obligation 
to 
prepare a LCDS, to 
report on the status 
of  implementation 
it 
and 
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public 

to  make 

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Planning  / 
Reporting 

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Decarbonisi
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the 

Monitoring 
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5 

Regulation 
(EU)  No 
525/2013 

Requirements 
Member 
national 
systems 

for 
States' 
inventory 

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525/2013 

Monitoring 
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Regulation 
(EU)  No 
525/2013 

6  

7  

September, 2024 

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Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

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Monitoring 
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9  

Regulation 
(EU)  No 
525/2013 

Monitoring 
Mechanism 
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10 

Regulation 
(EU)  No 
525/2013 

greenhouse 
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gas 

Requires  Member 
States 
report 
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11 

Regulation 
(EU)  No 
525/2013 

Retirement of units 
under 
the  Kyoto 
Protocol 

Other  

 N/A 

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Integrate  Article 58 

September, 2024 

392 

 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

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Art.   Description 
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Type 
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the 

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12 

Regulation 
(EU)  No 
525/2013 

Monitoring 
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13 

Regulation 
(EU)  No 
525/2013 

Monitoring 
Mechanism 
Regulation 

14 

Regulation 
(EU)  No 
525/2013 

Monitoring 
Mechanism 
Regulation 

15  

Regulation 
(EU)  No 
525/2013 

National systems of 
and 
policies 
measures 
and 
projections 

Reporting 
for 
obligations 
States 
Member 
related to reporting 
on  policies  and 
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the 

Reporting  

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September, 2024 

393 

 
 
Support for the Evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action 

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basis  

Art.   Description 
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Type 
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obligation  

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Correspond
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Monitoring 
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16 

Regulation 
(EU)  No 
525/2013 

Monitoring 
Mechanism 
Regulation 

17 

Regulation 
(EU)  No 
525/2013 

Monitoring 
Mechanism 
Regulation 

18 

Regulation 
(EU)  No 
525/2013 

adaptation 

Member 
States' 
reporting related to 
financial 
and 
technology  support 
provided 
to 
developing 
countries  

Reporting 
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UNFCCC and copies 
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396 

 
 
 
 
 
 
 
 
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