COMMISSION STAFF WORKING DOCUMENT Accompanying the document Communication from the Commission to the Eurppean Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Eu wide assessment of the final updated national energy and climate plans Delivering the Union's 2030 energy and climate objectives
Date: 2025-06-11
Institutions: Directorate-General for Energy, European Commission
Subjects: EU Member State, EU energy policy, EU environmental policy, adaptation to climate change, carbon neutrality, competitiveness, energy efficiency, investment, national planning, renewable energy

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 11.6.2025  SWD(2025) 140 final/2  This document corrects document SWD(2025)140 final of 27.05.2025  Removal of two paragraphs mentioning Malta’s assessment under Finland's assessment, on p. 227    The text shall read as follows: COMMISSION STAFF WORKING DOCUMENT Accompanying the document Communication from the Commission to the Eurppean Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Eu wide assessment of  the final updated national energy and climate plans      Delivering the Union's 2030 energy and climate objectives  {COM(2025) 274 final}  
 
 
Table of Contents 

Introduction ........................................................................................................... 3 

Bulgaria ................................................................................................................. 4 

Czechia ................................................................................................................ 15 

Denmark .............................................................................................................. 26 

Germany .............................................................................................................. 36 

Ireland ................................................................................................................. 47 

Greece ................................................................................................................. 57 

Spain .................................................................................................................... 68 

France .................................................................................................................. 78 

Croatia ................................................................................................................. 89 

Italy ................................................................................................................... 100 

Cyprus ............................................................................................................... 111 

Latvia ................................................................................................................ 120 

Lithuania ........................................................................................................... 131 

Luxembourg ...................................................................................................... 139 

Hungary ............................................................................................................. 148 

Malta ................................................................................................................. 159 

Netherlands ....................................................................................................... 169 

Austria ............................................................................................................... 180 

Portugal ............................................................................................................. 190 

Romania ............................................................................................................ 200 

Slovenia ............................................................................................................. 211 

Finland .............................................................................................................. 222 

Sweden .............................................................................................................. 233 

1 

 
 
 
 
 
 
 
 
 
Introduction 

This Staff Working Document provides a detailed assessment of how the final updated National 
Energy and Climate Plans (NECP) addressed the Commission recommendations on the draft 
updated plans.1  

The document includes the assessment of 23 plans as Belgium, Estonia and Poland had not 
submitted  their  final  plan  when  the  document  was  finalised.  Slovakia  submitted  their  final 
updated plan too close to the publication date for the assessment to be included. The assessment 
of these final plans will be published in a separate document.  

This assessment does not entail an approval by the Commission of the list of projects mentioned 
in the final NECPs.  

1 The draft NECPs, and the related Commission assessments and recommendations are available at this dedicated 
page: National energy and climate plans. 

2 

 
 
 
 
 
 
 
 
Bulgaria  

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Bulgaria’s final updated NECP 

2020 

Progress based on latest 
available data 

2030 national 
targets and 
contributions 

Assessment 
of 2030 
ambition 
level 

Binding target for 
greenhouse gas 
(GHG) emissions 
compared to 2005 
under the Effort 
Sharing Regulation 
(ESR) (%)  

Binding target for 
additional net 
GHG removals 
under the 
Regulation on 
Land Use, Land 
Use Change and 
Forestry 
(LULUCF) 

National 
target/contribution 
for renewable 
energy: 

Share of energy 
from renewable 
sources in gross 
final consumption 
of energy (%) 

National 
contribution for 
energy efficiency: 

Primary energy 
consumption  

2022: +9.9% 
2023: +4.9%2 

-10% 

NECP:  
-11.06% 

2022: Reported net 
removals of -9.54 Mt CO2 
eq.  

-1.16 Mt CO2 
eq. 
(additional 
removal 
target) 

 23.3% 
(SHARES) 

16% (target) 

2023: 22.5%  

34.96% 

16.90 Mtoe 

2023: 16.58 Mtoe 

13.19 Mtoe 

Insufficient 
ambition 
based on 
projections: 
A gap of 
1.45Mt CO2 
eq compared 
to the 2030 
target 

Bulgaria’s 
contribution of 
at least 34.96% 
is above the 
33% required 
under the 
formula set out 
in Annex II to 
the Governance 
Regulation3 

BG primary 
energy 
consumption 
contribution 

2 The ESR emissions in 2022 are based on 2024 final GHG inventory reports, and 2023 emissions are based on 
2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as set out 
in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions for 2021-
2025 will only be established in 2027 after a comprehensive review. 
3 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’). 

3 

 
 
 
 
 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
of 13.19 
Mtoe is in 
line with the 
EED recast 
Annex I 
formula 
results: 
13.71 Mtoe 
(Reference 
Scenario) or 
14.20 Mtoe 
(Updated 
Reference 
Scenario). 

BG final 
energy 
consumption 
contribution 
of 8.82 Mtoe 
is not in line 
with the 
national 
contribution 
of 8.42 Mtoe 
submitted by 
the 
Commission. 

BG 
surpassess 
the EU-wide 
interconnecti
vity target. 

Final energy 
consumption 

8.6 Mtoe 

2023: 9.59 Mtoe 

8.82 Mtoe 

Level of electricity 
interconnectivity 
(%)4 

11.3% 

2024: 16.8% 

15% 

Source: Eurostat; Bulgaria’s final updated national energy and climate plan. 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In April 2024, the Commission published a thorough assessment of Bulgaria’s draft updated 
NECP and provided recommendations5 for the preparation of the final updated NECP. Bulgaria 
submitted its final updated NECP on 14 January 2025, over six months after the deadline of 30 
June 2024.6 

2.1  DECARBONISATION 

Based  on  the  projections  provided  in  the  NECP,  Bulgaria  expects  to  decrease  total  GHG 
emissions (including LULUCF) by 78.2% in 2030 and by 92% in 2040 compared to 1990 and 

4  Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2024). The 2030 level 
represents the general interconnectivity target of 15%.  
5 SWD(2024) 125 final, and Commission Recommendation of 26 April 2024, C/2024/2905. 
6 Article 14(2) of Governance Regulation. 

4 

 
 
 
 
 
 
 
 
reaching net zero in 2050. Bulgaria’s NECP includes a commitment to climate neutrality by 
2050.  

2.1.1  Effort Sharing Regulation 
Bulgaria has addressed recommendation 1. The final NECP provides sufficient information 
on how Bulgaria will meet its ESR target of 10% by 2030 compared to 2005.  

The plan provides updated projections that mark an improvement compared to the draft plan, 
showing that the existing and planned policies and measures will lead to a decrease of 11.06% 
in 2030 compared to 2005, overachieving by 1.06 percentage points the national ESR target. 
In 2023, GHG emissions from ESR sectors represented 52% of the total in Bulgaria and are 
expected to be 47.8% in 20307.   

The  final  plan  complemented  the  information  on  the  policies  and  measures  provided  in  the 
draft but  could  still benefit from  a  clearer  description of their scope, timeline and  expected 
greenhouse gas reduction impacts. 

For what concerns transport, while the plan does not provide projections per sector under the 
ESR,  Bulgaria  expects  the  rate  of  emissions  reductions  in  total  transport  to  accelerate 
substantially, driven by for instance EV deployment low emission zones, biofuels deployment 
and hydrogen fuels. While several transport policies (both existing and planned) are outlined 
in  the plan, the concrete plans for implementation and/or scale up are not  always clear and 
robust implementation and monitoring will be key. The plan refers to the introduction of the 
emissions trading system for fuel combustion in buildings, road transport and additional sectors 
(ETS2). The WAM scenario projections account for the effect of ETS2, however they do not 
clearly consider the impact of ETS2 in achieving the ESR target. 

The  plan  does  not  provide  sufficient  detail  in  the  projections  on  agriculture.  The  sector  is 
described as the largest source of non-CO2 emissions, especially N2O from agricultural soils, 
although waste is also an important contributor. The plan outlines several relevant policies and 
measures for both sectors, but the lack of quantification of their impact makes it challenging to 
evaluate their effectiveness.  

2.1.2  LULUCF 
Bulgaria  has  partially  addressed  recommendation  3.  The  LULUCF  sector  in  Bulgaria 
generates net removals, absorbing roughly 16% of the total GHG emissions in 2022. Bulgaria 
has to improve its net removals by -1.163 Mt CO2eq in 2030 as compared to its yearly average 
in  the  2016-2018  reference  period.  However,  according  to  the  latest  reported  2022  figures, 
Bulgaria’s performance has worsened by 0.28 Mt CO2eq in comparison to the reference period. 
Moreover, taking into account its projections for 2030, Bulgaria will still have a gap of 1.45Mt 
CO2eq in 2030. The plan indicates additional policies for the LULUCF sector compared to the 
baseline scenario, but these are not sufficient to achieve the LULUCF target. 

The plan provides some information on how public funding (CAP, State aid) is used to reach 
the LULUCF target. The plan lacks information on the status and progress in ensuring higher 
tier levels and geographically explicit datasets needed to ensure the robustness of net removal 

7  Total  GHG  excluding  LULUCF.  Source:  EEA.  The  plan  does  not  include  disaggregated  information  on 
emissions from the ESR part of transport and buildings. 

5 

 
 
 
 
 
 
estimates. Overall, based on the available information, Bulgaria does not design sufficiently 
effective policies to support the land sector and the achievement of the LULUCF target. 

2.1.3  Carbon Capture and Storage 
Bulgaria has partially addressed recommendation 2. The plan provides some information 
on Carbon Capture Utilisation and Storage projects. One of the projects is expected to capture 
800 kt annually by 2028. Yet, the plan does not contain a comprehensive CCUS strategy and 
does not provide estimates for potential storage capacity, set annual injection capacity targets, 
or outline key national legislative proposals related to CCUS. 

2.1.4  Adaptation 
Bulgaria has partially addressed recommendation 4. The plan refers to the 2019 National 
Strategy for Adaptation and its Action Plan up to 2030, to respond to the recommendation and 
acknowledging the importance of integrating adaptation planning. However, the plan lacks, for 
most parts, adaptation policies and measures in the relevant Energy Union dimensions. The 
plan contains an overall analysis of climate vulnerabilities and risks through reference to a 
2023 study by the National Institute of Meteorology and Hydrology. However, it is short of 
quantifiable assessment of impacts. 

The plan does not set out significant additional adaptation policies and measures to support 
the achievement of national objectives, targets and contributions under the Energy Union It 
also  does  not  outline  the  link  to  the  specific  Energy  Union  objectives  and  policies,  that 
adaptation policies and measures are meant to support. The impacts and benefits of adaptation 
policies on other Energy Union objectives have generally not been quantified.  

2.1.5  Fossil Fuels 
Bulgaria has not addressed recommendation 18. The plan includes a commitment to phase 
down  fossil  fuels  for  energy  use  by  2038.  This  is  mentioned  only  as  part  of  broader 
decarbonisation  strategies  without  indicating  specific  actions  or  providing  quantitative 
information  on  build  in  alternative  renewable  capacities.  Moreover,  the  plan  does  not 
sufficiently explain the alignment between the NECP and TJTPs for Stara Zagora, Kyustendil, 
and  Pernik,  nor  the  intermediate  milestones  in  the  timeline  for  the  updated  coal  phase-out 
commitments.  

The plan states that Bulgaria does not provide fossil fuels subsidies, and hence does not include 
a timeline for their phase out8. 

2.2  RENEWABLES  

Bulgaria  has  partially  addressed  recommendation  5.  Indicative  trajectories  for  the 
deployment of renewable energy technologies over the 2020-2030 period are provided with the 
outlook  until  2050.  Bulgaria  sets  a  specific  target  of  6.2%  for  deployment  of  innovative 
renewable energy technologies by 2030. The plan also contains a specific target of 42.04% for 
renewable fuels of non-biological origin (RFNBOs) for industry by 2030. However, the plan 
does not include a specific target on the share of renewable energy to reach the indicative 1.6% 

8 The Commission 2024 study and  Report on Energy subsidies in the EU identifies the existence of fossil fuel 
subsidies. 

6 

 
 
 
 
 
 
target for industry by 2030. Neither does the plan provide an indicative share of renewables for 
district heating and cooling over the period 2021-2030. 

Bulgaria  has  partially  addressed  recommendation  6  and  8.  The  final  plan  provides  no 
further  information  on  the  uptake  of  power  purchase  agreements.  For  renewable  energy 
deployment in the heating and cooling sector, Bulgaria indicates that the share of renewables 
will  reach  44.01%  in  2030,  with  the  aim  to  promote  innovative  geothermal  and  solar 
technologies, and the use of waste heat and cold. The plan projects that the share of renewable 
energy  in  transport  will  increase  to  29.93%  by  2030,  which  will  include  a  contribution  of 
renewable  fuels  of  non-biological  origin.  As  regards  the  obligation  of  fuel  suppliers  in 
transport, the plan refers to  specific obligations on fuel  and energy suppliers  for  a range of 
renewable fuels without providing further details and does not mention specific measures for 
promoting  renewable  fuels  of  non-biological  origin  in  industry.  Geothermal  energy  will  be 
promoted via the deployment of heat pumps.  

While the use of biomass will remain the largest share of renewables in heating and cooling in 
2030,  it  would  have  to  comply  with  the  stricter  sustainability  requirements  in  line  with 
Directive (EU) 2018/2001 (the ‘revised RED II’)9 and its share gradually will decrease over 
the  next  decades.  No  additional  detail  has  been  provided  in  the  final  plan  on  the  specific 
measures, except the aim to develop a vision for the development of the heat market and access 
of small producers to district heating networks.  

Measures to further accelerate permitting procedures and define renewables accelerated areas 
are mentioned in the context of implementing the requirements of the revised RED II. A plan 
for the identification of priority areas (Renewables Accelerated Areas) for the development of 
wind power generation sites is currently under development.  The plan does not contain details 
on procedural steps leading to the adoption of measures aimed at implementing provisions of 
the revised RED II.  

Bulgaria  has  partially  addressed  recommendation  7.  The  updated  plan  provides  the 
estimated trajectories for biomass demand by sector and biomass use by origin. But it does not 
assess  the  domestic  supply  of  forest  biomass  for  energy  purposes  in  2021-2030  nor  the 
compatibility  of  the  projected  use  of  forest  biomass  for  energy  production  with  Bulgaria’s 
obligations  under  the  revised  LULUCF  Regulation.  Bulgaria  does  not  provide  measures  to 
support sustainable biogas and biomethane production, resulting in reduction of current biogas 
production in 2030 target. 

2.3  ENERGY EFFICIENCY DIMENSION 

Bulgaria has not addressed  recommendation 9. Bulgaria does not  include the  amount of 
energy  consumption  reduction  per  year  to  be  achieved  by  all  public  bodies  as  required  by 
Article 5 of Directive (EU) 2023/1791 (‘EED recast’)10.  Bulgaria does not report the total floor 
area of heated and cooled buildings owned by public bodies to be renovated yearly - nor the 

9 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  
10 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 

7 

 
 
 
 
 
 
corresponding yearly energy savings to be achieved and it also does not specify if it opted for 
an alternative or default approach. Bulgaria sets out some policies and measures to achieve the 
reduction of energy consumption from public bodies and the renovation of public buildings, 
including the introduction of building information modelling at national level.   

Bulgaria  has  partially  addressed  recommendation  10.  Bulgaria  sets  out  policies  and 
measures to achieve the national contributions on energy efficiency, but it does not quantify 
the expected energy savings and the contribution for each of the reported energy efficiency 
measures, except for those measures contributing to the energy savings obligation under Article 
8  of  EED  Recast.  Considering  the  latter  provision,  Bulgaria  also  includes  the  amount  of 
cumulative energy savings of 6.2 Mtoe to be achieved over the period from 1 January 2021 to 
31  December  2030  and  includes  an  explanation  on  how  the  annual  savings  rate  and  the 
calculation baseline were established. Bulgaria does not quantify the savings from those energy 
efficiency measures targeting energy poverty.   

Bulgaria  specifies  robust  energy  efficiency  financing  programmes  and  support  schemes, 
including financial instruments and public guarantees, able to mobilise private investments and 
additional co-financing. Bulgaria specifies existing policy measures to promote the uptake of 
energy  efficiency  lending  products  and  innovative  financing  schemes  (such  as  Energy 
Performance Contracts - ESCOs). Bulgaria establishes a National Energy Efficiency Fund and 
details its role, as defined in Article 30 of EED Recast, in helping deliver the energy efficiency 
national contributions to the EU target, by including the use of financial instruments within the 
Fund.  

Bulgaria has partially addressed recommendation 11. The plan does not raise the ambition 
of the 2020 long-term renovation strategy (LTRS) but recalls some of its key elements, such 
as the energy savings, renovated area and CO2 savings milestones for 2030, 2040 and 2050. 
The plan describes additional measures and initiatives relating to building renovations, which 
were not identified in the 2020 NECP. 

The plan includes sufficient information on related measures for buildings in terms of funding 
and  costs  but  only  includes  partial  information  on  energy  and  emission  savings.  The  plan 
includes  specific  information  on  policies  and  measures  addressing  deep  renovation  (with  a 
specific  focus  on  vulnerable  consumers)  and  decarbonisation  of  heating  or  installation  of 
renewables in buildings but not on worst performing buildings.  

2.4  ENERGY SECURITY DIMENSION 

Bulgaria  has  partially  addressed  recommendation  12.  The  final  plan  does  not  further 
explain  how  Bulgaria  will  diversify  its  gas  supply  and  does  not  concretely  explain  how 
Bulgaria intends to continue encouraging gas demand reduction towards 2030. It does however 
provide  a  forecast  for  the  future  role  of  natural  gas.  In  the  WAM  scenario,  primary  energy 
production from natural gas is expected to marginally decrease first, from 169 GWh in 2022 to 
164 GWh in 2030, and then much more quickly, to 50 GWh in 2040 and 8 GWh in 2050. In 
the  WEM  scenario,  however,  primary  energy  production  from  natural  gas  increases  to  190 
GWh by 2030, and then decreases to 168 GWh by 2040.   

The  final  plan  does  not  contain  any  additional  information  on  storage  targets,  only  a  few 
additional projects.  

8 

 
 
 
 
 
The plan does not assess the adequacy of the oil infrastructure (pipelines,  refineries, and oil 
storage) in the long run with the expected oil demand decline and the move to lower-carbon 
alternatives. 

It also does not address the imperative of climate adaptation on the energy system, with no new 
measures. 

The  plan  describes  measures  to  diversify  the  supply  of  nuclear  fuel  but  does  not  provide 
information on spare parts and services. It mentions small modular reactors and implementing 
good practices in radioactive waste management and spent nuclear fuel management, without 
giving further details. 

2.5  INTERNAL ENERGY MARKET DIMENSION 

Bulgaria  has  partially  addressed  recommendation  13.  The  plan  elaborates  on  the 
quantification  of  flexibility  needs  although  not  in  a  structured  way,  nor  does  it  set  specific 
demand response targets beyond measures enabling participation of demand response. The plan 
does however provide clear targets to improve the flexibility of the energy system. Bulgaria 
notably  aims  to  increase  flexibility  by  enabling  a  non-discriminatory  participation  of  new 
flexibility  services,  demand  response  aggregation,  intraday  and  day-ahead  markets,  and 
expanded interconnectors. 

The  final  plan  does  not  provide  information  on  specific  measures  aimed  at  energy  system 
integration to facilitate system integration of renewable electricity in accordance with Article 
20a of the revised RED II.  

The  plan  defines  forward-looking  objectives  and  targets  concerning  market  integration. 
Bulgaria is actively participating in cross-border market coupling initiatives, including SIDC 
for  intraday  trading  and  SDAC  for  day-ahead  markets.  The  plan  also  outlines  projects  for 
integration with Serbia, North Macedonia, and Greece. There are plans to fully liberalise the 
market by 2025 and steps are being taken on different measures relevant to retail markets such 
as dynamic electricity pricing, aggregator participation, and local energy communities. When 
introduced, the removal of public supplier quotas and price caps for balancing electricity will 
further  contribute  to  develop  competitive  wholesale  markets  and  to  phase  out  measures 
interfering with market signals, ultimately aligning with EU market rules. 

Bulgaria  has  partially  addressed  recommendation  14.  The  updated  NECP  contains  a 
description on the adopted legal definition of energy poverty (i.e. modification to the Energy 
Act) along with reference to current measures. Moreover, the role and the tasks of the energy 
poverty observatory are better described. The plan also provides more explanations on energy 
efficiency  measures.  Some  estimates  of  the  total  number  of  poor  individuals  has  been 
improved, but an official system to identify and monitor those in energy poverty has not been 
developed  yet.  However,  this  could  be  elaborated  further  to  include  an  energy  poverty 
reduction target and indicative timelines for the implementation of support schemes and the 
identification mechanism itself.  In terms of financing the following is indicated: EU Social 
Climate Fund, other financial instruments with an EU funding source and the national budget. 
This could be explained more concretely as well.  

9 

 
 
 
 
 
 
2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Bulgaria  has  partially  addressed  recommendation  15.  The  plan  includes  a  partially 
comprehensive  approach  referring  to  the  decarbonisation  of  the  sectors  of  the  economy, 
however it does not include targets to support research, innovation and competitiveness in clean 
energy technologies. In terms of share of GDP public spending, the pathway towards 2030 and 
beyond is not  established. Instead, Bulgaria refers to numerous mid-term European funding 
programmes (2021-2027) as the main source of funding supporting energy transition and clean 
technologies investments.  

The plan includes some measures to promote the development of net-zero projects including 
those relevant  for  energy intensive industries, for example in  the area of hydrogen and low 
carbon gasses, the National Roadmap for hydrogen (which was adopted in 2023) and the act 
on AttractInvestBG for facilitating investments through industrial parks. The plan refers in a 
general way to the simplified permitting procedures for manufacturing, and more specifically 
to  projects  having  the  status  of  the  Projects  of  Common  Interest  (PCI,  TEN-E).  The  plan 
includes information on policies and measures for the development of clean energy and digital-
related skills. 

It partly addresses the supply chains of key net-zero components and equipment, through the 
investments in the industrial parks, such as for the electricity sector, and hydrogen.  

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Bulgaria has not addressed recommendation 16. The plan does not provide an estimate of 
the total investment needs. It focuses mainly on investments in new renewable energy sources, 
electricity,  and  heat  production.  Though  this  assessment  is  based  on  a  sound  methodology, 
relying  primarily  on  a  top-down  approach,  investment  needs  in  other  sectors  are  not  fully 
described. The proportion of public investment  is  unclear,  and the tools to  mobilise private 
investment  are not  described. The plan includes  a list  of EU financial sources but does not 
consider  national  and  regional  public  sources.  The  types  of  financial  instruments  are  not 
detailed.  

Bulgaria does not provide a robust macroeconomic impact assessment. It presents different 
policy scenarios and assesses their impact on carbon intensity, energy prices, and investment. 
However,  the  plan  does  not  establish  a  direct  and  quantifiable  link  between  specific  policy 
measures  and  their  macroeconomic  impact  and  has  limitations  concerning  the  model-based 
analysis  of  GDP  and  employment.  The  impacts  on  health  and  environment  are  described 
qualitatively.  

2.8  JUST TRANSITION 

Bulgaria has partially addressed recommendation 20. The plan provides information on the 
impact of the transition to climate neutrality on employment (with quantitative information on 
jobs in the construction sector) and skills but does not sufficiently address the impact on the 
most  vulnerable  households.  Moreover,  the  plan  does  not  specify  the  form  of  support,  the 
impact of initiatives or the resources available, except for the Just Transition Fund (JTF) and 

10 

 
 
 
 
 
the Modernisation Fund. The analysis focuses on the JTF and the Territorial Just Transition 
Plans.  

The coal phase-down deadline in the TJTPs (Stara Zagora, Kyustendil, and Pernik) is aligned 
with  the final  updated NECP, but  the latter does not clarify concrete actions to  respect this 
timeline.  

The plan lacks the analytical basis needed for the preparation of the Social Climate Plan, such 
as information on the estimated impact of ETS2 and the identification of vulnerable groups. 
The  plan  does  not  fully  explain  how  the  policy  framework  identified  in  the  NECP  will 
contribute to the preparation of Bulgaria’s Social Climate Plan nor how the consistency of the 
two plans will be ensured.  

2.9  PUBLIC CONSULTATION 

Bulgaria  has  partially  addressed  recommendation  21.  Bulgaria  organised  public 
consultations on the draft NECP, mainly organised through the official websites. The Bulgarian 
authorities  responsible  for  the  NECP  also  participated  to  various  conferences,  meetings, 
roundtables, and stakeholder fora. The public consultation started on 22 December 2023 and 
lasted  a  month.  This  was  rather  close  to  date  of  the  submission  of the  draft  plan  (February 
2024), which might have limited the ability to fully take stakeholder input into account early 
in the process.  

The plan includes a summary of the outcome of the consultations but does not describe how 
the  final  plan  integrates  the  inputs  suggested  from  stakeholders.  The  plan  indicates  that  an 
extensive  consultation  process  on  the  final  NECP  is  expected  to  be  launched  after  the 
submission  of  the  final  updated  NECP.  The  final  plan  is  subject  to  strategic  environmental 
assessment. 

2.10 REGIONAL COOPERATION 

Bulgaria has partially addressed recommendation 22. The plan includes a comprehensive 
list  of  electricity,  gas,  and  renewable  energy-related  regional  initiatives  under  the  CESEC 
High-Level  Group, aiming at increasing Bulgaria’s engagement with neighbouring Member 
States  and  Energy  Community  Contracting  Parties,  thus  enhancing  Bulgaria’s  security  of 
supply, market integration and integration of renewable energy. While detailed information on 
several  regional  initiatives  within  CESEC  is  provided,  the  plan  does  not  mention  the  key 
CESEC  priority  of  gas  quality  harmonisation,  which  is  essential  for  unblocking  the  full 
potential of the Trans-Balkan pipeline in reverse flow. This infrastructure route, that connects 
Greece  through  Bulgaria,  Romania  and  Ukraine  with  the  CEE  gas  markets,  has  been 
significantly underutilised due to different gas quality parameters across borders. The final plan 
does  not  describe  how  Bulgaria  plans  to  establish  a  framework  for  cooperation  with  other 
Member States by 2025, in line with Article 9 of the revised RED II. 

The  plan  does  not  refer  to  any  progress  nor  efforts  for  the  signature  of  the  two  bilateral 
solidarity agreements for the security of gas supply with Bulgaria’s neighbours (Romania and 
Greece). 

11 

 
 
 
 
 
2.11 ANALYTICAL BASIS 

Bulgaria  has  addressed  recommendation  19.  The  plan  provides  both  With  Existing 
Measures and With Additional Measures scenarios with projections until 2050.  

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

Bulgaria has partially addressed recommendation 17. The plan covers sufficiently the main 
reforms  and  investments  of  the  Recovery  and  Resilience  Plan  (RRP) 11 that  contribute  to 
implementing the objectives, targets, and contributions of the Energy Union. The final updated 
NECP  still  does  not  refer  to  Investment  8  (C4.I8):  National  infrastructure  for  storage  of 
electricity  from  renewables  (RESTORE),  which  would  enable  the  installation  and 
commissioning  of  a  national  infrastructure  of  grid-scale  electricity  storage  facilities  with  at 
least 3000 MWh of usable energy capacity under the RRP. Some reforms addressed in the final 
NECP have not been adequately recognized as part of the RRP, such as the reform of the Act 
on Energy from Renewable Sources.  

3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

The Commission encourages Bulgaria to ensure a timely and complete implementation of the 
final updated NECP. Bulgaria is invited to pay particular attention to following main elements: 

•  Monitor the impact of policies to decarbonise transport, including planned measures to 
support the uptake of electric vehicles and the construction of recharging infrastructure, to 
enable modal shift and low emission zones.  

•  On  LULUCF,  increase  monitoring  and  enforcement  of  sustainable  forest  management 
practices, consider additional measures including afforestation, agroforestry, and improve 
the targeting and the commitments of existing interventions such as those under the CAP.    
•  On adaptation, assess quantitatively the relevant climate vulnerabilities and risks for the 
national objectives, targets, and contributions and the policies and measures in the different 
Energy Union dimensions. That would enable better outlining and quantifying the link to 
the specific Energy Union objectives and policies, that adaptation policies and measures 
are meant to support. 

•  On  fossil  fuels,  enable  the  gradual  phase-out  of  solid  fossil  fuels  in  view  of  the  2038 
deadline set by the plan. Identify fossil fuel subsidies and outline a roadmap for their phase-
out. 

•  On industry, put in place robust measures to decarbonise industry, including by reducing 
energy consumption, as the share of energy consumed by industry is projected to decrease 
less  than  in  other  sectors.  Develop  a  framework  to  support  the  uptake  of  renewable 
hydrogen and CCUS.  

11 Bulgaria does not have a REPowerEU chapter as of May 2025. 

12 

 
 
 
 
 
 
 
•  Commit  public  and  private  R&I  funding  to  the  clean  energy  transition  and  innovative 
technologies  and  industries.  Foster  additional  synergies  in  the  SET-Plan,  including  on 
institutional capacity building and synergies with European funding programmes. 

•  On  renewable  energy,  identify  renewable  acceleration  areas  for  simplified  permitting 
procedures  and  outline  a  comprehensive  plan  to  increase  renewables  uptake  in  district 
heating  and  cooling.  Commit  to  the  plan  to  upgrade  the  electricity  grid  to  integrate 
increased  shares  of  renewable  energy.  Put  in  place  a  framework  to  enable  renewables 
power purchase agreements to provide certainty to all market actors. 

•  On energy efficiency, put  in  place measures to  achieve the higher ambition  for  energy 

efficiency by 2030.  

•  On buildings, ramp up the pace and depth of renovation in overall building stock and assess 

market barriers to speed up the implementation of the measures put forward.  

•  On the flexibility on the electricity market, boost competition on the electricity market 
and  enable  the  rapid  deployment  of  non-fossil  flexibility  to  further  increase  system 
flexibility.  

•  On nuclear energy, continue efforts  to  diversify nuclear fuel  supplies and to  ensure its 

long-term supply of spare parts and maintenance services. 

•  Adopt  a  more  comprehensive  just  transition  strategy  that  addresses  the  impact  on 

vulnerable households and allocates sufficient funding.  

•  On  regional  cooperation,  streamline  cooperation  on  the  gas  quality  harmonisation  in 
CESEC  which  is  essential  for  unblocking  the  Trans-Balkan  pipeline  and  enhancing 
Bulgaria’s and regional security of supply.  

13 

 
 
 
 
 
 
 
 
Czechia 

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Czechia’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for 
additional net GHG 
removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 

Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

 17.3% 
(SHARES) 

13% 
(target) 

National contribution for 
energy efficiency: 

2022: -6.7%% 
2023: -5.7%12 

-26% 

NECP:  
-35.8% 13 

2022: Reported 
net emissions  
of 11.268 Mt 
CO2 eq.  

-0.83Mt CO2 
eq. (additional 
removal 
target) 

Insufficient 
ambition, 
projected gap of 
0.25Mt CO2eq 

2023: 18.5% 

30.1% 

Primary energy 
consumption  

44.3 
41.4Mtoe 

2023: 35.49 
Mtoe 

29.19 Mtoe 

Czechia’s 
contribution of 
30.1% is below 
the 33% required 
according to the 
formula set out in 
Annex II of the 
Governance 
Regulation14 

CZ primary 
energy 
consumption 
contribution of 
29.19 Mtoe is in 
line with the EED 
recast Annex I 
formula results: 
28.81 Mtoe 
(Reference 
Scenario) or 29.18 
Mtoe (Updated 

12 
The  ESR emissions  in 2022 are based on  2024  final  GHG inventory  reports, and 2023 emissions are 
based on 2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as 
set out in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions 
for 2021-2025 will only be established in 2027 after a comprehensive review. 
13   
The emissions reductions by 2030 are measured against the 2005 emission level as set out in Commission 
Implementing Decision (EU) 2020/2126 of 16 December 2020. For Czechia this number is 64.965295 MtCO2 eq. 
in 2005. 
14 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’) 

14 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
Final energy consumption 

25.3 Mtoe 

2023: 22.61 
Mtoe 

20.35 Mtoe 

Level of electricity 
interconnectivity (%) 

27.5% 

2024: 27.0% 

15%15 

Source: Eurostat; Czechia’s final updated national energy and climate plan 

Reference 
Scenario) 

CZ final energy 
consumption 
contribution of 
20.35 Mtoe is in 
line with the 
national 
contribution of 
20.35 Mtoe 
submitted by the 
European 
Commission. 

CZ has surpassed 
the EU-wide 
interconnectivity 
target. 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In  December  2023,  the  Commission  published  a  thorough  assessment  of  Czechia’s  draft 
updated NECP and provided recommendations16 for the preparation of the final updated NECP.  
Chechia submitted its final updated NECP on 20 December 2024, almost six months after the 
deadline of 30 June 2024.17 

2.1  DECARBONISATION 

Czechia expects to decrease total GHG emissions (including LULUCF) by 68% by 2030, 86% 
by 2040 and 96% by 2050 compared to 1990.  

2.1.1  Effort Sharing Regulation 
Czechia has addressed recommendation 1. The final plan provides sufficient details on how 
Czechia  will  meet  its  ESR  target  of  -26%  by  2030  compared  to  2005.  The  plan  provides 
updated projections showing that the existing and planned policies and measures will lead to a 
decrease of 35.8% of ESR emissions in 2030 compared to 2005, overachieving the national 
ESR target by 9.8 percentage points. In 2023, GHG emissions from ESR sectors represented 
56.7% of the total in Czechia (will be 64.3% in 2030)18, with transport and buildings projected 

15  Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2022-2023). The 2030 
level represents the general interconnectivity target of 15%. The level of ambition cannot be assessed, because 
the actual 2030 interconnectivity levels will depend on the implementation of the planned interconnectors and 
changes in the generation capacity. The 2020 figure covers also interconnectors with the neighbouring countries 
outside the EU. 
16  SWD  (2023)  926  final,  and  Commission  Recommendation  of  18  December  2023,  C/2023/9616.  The 
recommendation  from  18  December  2023  was  supplemented  with  a  revised  recommendation  regarding  ESR 
adopted in February 2024, C/2024/1175. 
17 Article 14(2) of Governance Regulation. 
18 Total GHG excluding LULUCF. Source: Commission calculations based on the Czech final updated NECP  

15 

 
 
 
 
 
 
 
 
to represent the largest shares.19 The with additional measures (WAM) projected value for ESR 
in  2030  is  roughly  12.6%  lower  than  the  with  existing  measures  (WEM),  hinting  that 
implementing  the  plan  will  require  a  significant  effort.  Notably  the  plan  recognises  the 
difficulties in reducing emissions in the transport and buildings sectors. The final plan did not 
complement  the information  on the policies  and  measures provided in  the draft  in  terms of 
scope, timeline and expected impact on GHG emissions.  

On  transport,  the  WAM  projections  describe  a  change  of  trend  in  emissions  in  the  period 
2025-2030,  with  an  annual  percentage  decrease  of  2.5%  following  a  steady  increase  of 
emissions by 0.42% per year in the period 2015-2025.20 Czechia has indicated a number of 
existing  and  planned  measures  for  the  transport  sector,  including  further  electrification  of 
railways and urban public transport, gradual shift to freight transport from road to rail and/or 
waterborne  transport,  tax  incentives,  use  of  alternative  fuels.  However,  it  is  unclear  which 
remain to be implemented, or which will be scaled up to reach the ESR target. 

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings,  road  transport  and  additional  sectors  (ETS2).  It  is  unclear  if  the  WAM  scenario 
projections account for the effect of ETS2. The projections do not quantify the impact of ETS2 
in achieving the ESR target.  

On agriculture, the projected non-CO2 emissions are lower than in the draft plan, despite 
policies being the same. The main measures mentioned in the plan concern biogas and organic 
farming, but limited details are provided. The plan does not provide sufficient detail in terms 
of  funding  and  impacts  of  measures.  The  projections  reflect  a  stagnation  of  emission  from 
agriculture in 2030, indicating a need for targeted policies and actions. The emission savings 
expected from policies addressing HFCs and other fluorinated gases, including as a result of 
the newly reinforced Regulation (EU) 2024/573 (F-gas Regulation), remain unclear.  

The  plan  describes  various  waste  management  and  circular  economy  strategies,  promoting 
waste reduction, recycling and recovery. However, the plan remains unclear on how to tackle 
CH4  from  landfills,  failing  to  mention  effective  mitigation  solutions  such  as  separate 
collection, landfill gas capture and anaerobic digestion. 

2.1.2  LULUCF 
Czechia  has  partially  addressed  recommendation  3.  The  LULUCF  sector  in  Czechia 
generates  net  emissions,  representing  roughly  2.9%  of  the  total  GHG  emissions  in  2022. 
According to the LULUCF Regulation, Czechia has to enhance its net removals by -0.827 Mt 
CO2eq in 2030 as compared to the yearly average in the 2016-2018 reference period. However, 
according to the latest reported 2022 figures, Czechia’s performance has worsened by 14.5 Mt 
CO2eq  in  comparison  to  the  reference  period.  The  gap  to  comply  with  the  “no-debit” 
commitment  in  2025  is  expected  to  be  significant.  A  considerably  smaller  gap  of  0.25  MT 
CO2eq is expected towards reaching the 2030 target.  Despite the fact the policies and measures 
are the same as in draft plan, the updated plan shows a reduced gap towards the 2030 target. 
The  difference  is  due  to  more  optimistic  assumptions  on  the  decline  of  the  bark  beetle  and 

19 Source: EEA. The plan does not include disaggregated information on emissions from the ESR part of transport 
and buildings.  
20 Compound annual growth rate. 

16 

 
 
 
 
 
 
forest restoration, resulting in more removals. The plan lacks sufficient information to quantify 
the contribution of policies and measures to the LULUCF target. In view of the persistent gap, 
Czechia does not design sufficiently effective policies to support the performance of the land 
sector. 

Czechia  acknowledges  that  the  level  of  accuracy  of  reporting  of  LULUCF  emissions  and 
removals needs to be improved. However, the plan does not provide sufficient information on 
the status and progress in ensuring higher tier levels and geographically explicit datasets needed 
to ensure the robustness of net removal estimates. 

2.1.3  Carbon Capture and Storage 
Czechia has not addressed recommendation 2 on CCUS. The NECP still does not provide 
estimates on emissions to capture annually by 2030. Yet, the plan provides CO2 capture targets 
from 2035 onwards by source, and indicates Czechia is in the process of preparing a CCUS 
strategy.  

2.1.4 Adaptation 
Czechia  has  partially  addressed  recommendation  4.  The  plan  refers  to  the  National 
Adaption  Plan  for  Climate  Change,  the  National  Climate  Change  Adaptation  Strategy,  and 
Czechia´s  Common  Agricultural  Policy  Strategic  Plan  2023-2027  to  respond  to  the 
recommendation, acknowledging the importance of integrating adaptation planning. The plan 
partially embeds adaptation policies and measures in the relevant Energy Union dimensions.  

The plan contains a partial analysis of climate vulnerabilities and risks, especially in the land-
use  sector  and  the  energy  security  dimension.  The  plan  identifies  several  significant  risks 
related to drought and other extreme weather events. The plan also outlines adequate policies 
and measures to address these vulnerabilities and risks but is short of quantifiable assessment 
of impacts. The plan partially outlines the links to the specific Energy Union objectives and 
policies,  that  adaptation  policies  and  measures  are  meant  to  support.  The  formulation  of 
adaptation goals has progressed through inclusion of goals on energy security.  However, the 
impacts and benefits of adaptation policies on other Energy Union dimensions have generally 
not  been  quantified.  The  plan  sets  out  some  additional  adaptation-related  policies  and 
measures to support the achievement of national objectives, targets and contributions under 
the  Energy  Union,  such  as  investments  aiming  at  minimising  environmental  impacts  (e.g. 
biodiversity loss).  

2.1.5  Fossil Fuels 
Czechia has not addressed recommendation 19. The plan recognises one fossil fuel subsidy 
(housing allowance), which Czechia does not plan to phase out, due to its role to encourage 
environmentally friendly heating methods and provide social support. It also provides a list of 
subsidies in energy transformation, energy extraction and agriculture which Czechia does not 
consider fossil fuel subsidies. The plan   lacks clear measures and a timeline to phase out fossil 
fuel subsidies.  

2.2  RENEWABLES  

Czechia has partially addressed recommendation 5. The final NECP includes a contribution 
for a renewable energy share of 30.1% in gross final energy consumption for 2030, which is 
similar to the one submitted in the draft plan and below the level of 33% resulting from the 

17 

 
 
 
 
 
formula of Annex II of the Governance Regulation. Czechia also provides a reference point for 
2025 of around 23% which is in line with the trajectory calculated with the increased EU 2030 
renewable energy target of 42.5%. However, no information has been provided on the 2027 
reference point.  

Czechia  has  partially  addressed  recommendation  6.  The  final  NECP  includes  specific 
targets,  namely  the  target  to  contribute  to  the  sub-target  for  buildings  for  2030  (40%),  an 
average increase in heating and cooling of 1.4 pps for the period 2021-2025 and 1.9 pps for 
2026-2030,  in  line  with  the  binding  target  of  Article  23  of  Directive  (EU)  2018/2001  (the 
‘revised RED II’)21, but below the level of the indicative top-ups, as well as targets for advanced 
biofuels and renewable fuels of non-biological origin (RFNBOs) in transport by 2030 (5% and 
1% respectively). The final plan however does not include a target for innovative renewable 
energy technologies by 2030 or an indicative target in district heating and cooling for the period 
2021-2030.  The  plan  does  not  contain  a  specific  target  for  the  renewable  energy  share  in 
industry.   

Czechia has partially addressed recommendation 7. Czechia refers to its plans to designate 
“renewables acceleration areas”, but it does not elaborate further. It also includes information 
on recent measures to promote self-consumption and energy communities, and information on 
the  New  Green  Savings  2030  programme  which  will  support  the  installation  of  small-scale 
renewable energy installations for self-consumers and energy communities. Czechia indicates 
that  it  plans  to  support  the  modernisation  of  the  existing  heat  systems  to  make  them  more 
efficient, including by introducing new small decentralised renewable heating systems, but no 
granular information or quantitative data has been provided. Czechia has not provided further 
information  on  how  it  plans  to  accelerate  the  deployment  of  renewables  via  the  uptake  of 
renewable  power  purchase  agreements  or  guarantees  of  origin.  The  plan  does  not  contain 
specific information on the measures to accelerate deployment of renewables in district heating 
and cooling, nor on creating an enabling framework for increasing the integration between the 
electricity and heating and cooling networks.   

Czechia has addressed  recommendation 8. Czechia includes further measures to promote 
the sustainable production of biomethane.  

Czechia  has  not  addressed  recommendation  9.  The  plan  does  not  contain  an  expected 
timeline of the procedural steps leading to the adoption of measures to transpose and implement 
the revised RED II. 

2.3  ENERGY EFFICIENCY DIMENSION 

Czechia has partially addressed recommendation 10. Czechia included an amount of energy 
consumption reduction of 15.2 Mtoe1 per year to be achieved by all public bodies but without 
disaggregating it by sector. Czechia reported the corresponding yearly energy savings to be 
achieved but it did not specify if they opted for the alternative or default approach. Czechia set 

21 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  

18 

 
 
 
 
 
 
out policies and measures to achieve the reduction of energy consumption from public bodies 
and the renovation of public buildings.  

Czechia has partially addressed recommendation 11. Czechia set out complete policies and 
measures to achieve the national contributions on energy efficiency. Czechia specified how the 
energy efficiency first  principle will be implemented and mentioned a consortium set  up to 
carry out and monitor its implementation. 

Czechia set out complete policies and measures to achieve the required amount of cumulative 
end-use energy savings by 2030 and it quantified the energy savings from the reported energy 
efficiency  measures  to  ensure  the  achievement  of  the  cumulative  target3,  including  those 
measures targeting energy poverty. 

Czechia  specified  robust  energy  efficiency  financing  programmes  and  support  schemes, 
including financial instruments and public guarantees, able to mobilise private investments and 
additional co-financing. Czechia specified existing policy measures to promote the uptake of 
energy  efficiency  lending  products  and  innovative  financing  schemes  (such  as  Energy 
Performance Contractors, ESCOs). 

Czechia has addressed recommendation 12. Czechia details the impact in terms of energy 
savings of each new measures put forward on buildings. The final updated NECP presents an 
ambitious scenario according to which most buildings (85%) will be deeply renovated from 
2025  to  2030.  Only  buildings  where  this  is  not  technically  possible  will receive  shallow  or 
medium  renovations.  In  addition,  the renovation  rate will be  approximately  doubled, which 
would mean that every building will be renovated over a period of less than 30 years. This 
increase in depth and renovation rates is expected to lead to a reduction in energy consumption 
by 166 PJ (44%) in 2050. 

2.4  ENERGY SECURITY DIMENSION 

Czechia has partially addressed recommendation 13. Czechia does not further set out how 
it intends to continue encouraging gas demand reduction towards 2030. It also does not provide 
exact estimates for the evolution of natural gas consumption, noting only that the share of gas 
in the energy mix is expected to increase to 21% of primary energy consumption by 203022, 
and then decrease until 7% by 205023.  

Czechia clarifies that the development and installation of energy storage systems is a priority. 
In a report on the flexibility of the Czech electricity system, Czechia is analysing the impact of 
the energy transition  on flexibility  needs, which will be followed by an action plan, setting 
priorities for the development of non-fossil flexibility and defining the objective for flexibility 
of non-fossil sources, including energy storage for the next ten years. 

The  final  updated  NECP  describes  measures  taken  to  ensure  security  of  supply  of  nuclear 
materials and fuel but does not provide information on spare parts and maintenance services. 
The plan includes some information on plans to develop Small Modular Reactors (SMRs) and 

22 Total primary energy consumption in 2030 is expected to be 1 206PJ, according to the plan. 
23 According to Eurostat data, this share was of approximately 15% in 2022, for a total gross inland consumption 
of around 1 754 PJ: 
 https://op.europa.eu/en/publication-detail/-/publication/993e1f3f-89d1-11ef-a67d-01aa75ed71a1/language-en  

19 

 
 
 
 
 
 
notes  that  the  Atomic  Act  is  being  amended  to  include  SMR  technology.  The  first  SMR  is 
expected to become operational in the mid-2030s, with the total installed capacity of SMRs 
reaching up to 3 GW depending on the construction of large reactors. In addition to electricity 
generation, the use of SMRs is considered for district heating systems. 

The final updated NECP does not provide information on measures taken to ensure the long-
term management of nuclear waste. This is however covered in the 4th national report submitted 
in 2024 in accordance with Article 14 of Directive 2011/70/EURATOM24. 

The plan addresses the need to diversify from Russian oil imports however it does not assess 
the adequacy of the oil infrastructure (pipelines, refineries, and oil storage) in the long run with 
the expected oil demand decline and the move to lower-carbon alternatives. 

The final plan refers to the energy system’s vulnerabilities identified in the National Climate 
Change Adaptation Strategy. However, it still does not contain information about the concrete 
envisaged measures to prepare for it. 

2.5  INTERNAL ENERGY MARKET DIMENSION 

Czechia has partially addressed recommendation 14. Czechia does not put forward clear 
objectives  and  targets  for  demand  response  to  improve  the  flexibility  of  the  energy  system 
underpinned by an assessment of the flexibility needs. The plan also does not describe specific 
measures to facilitate energy system integration in the context of implementing provisions of 
Article 20a of the revised RED II. However, Czechia is working on a report on flexibility of 
the  Czech  electricity  system,  which  examines  the  assessment  of  the  flexibility  needs  of  the 
energy  system.  The  report  will  analyse  the  impact  of  phasing  out  fossil  fuels  on  flexibility 
needs  as  well  as  the  potential  for  flexibility  in  the  period  2025-2030.  This  report  will  be 
followed  by  an  action  plan  setting  priorities  for  the  development  of  non-fossil  flexibility, 
defining objectives on their development for the next ten years.  

Czechia has been taking  steps to  increase the level  of  consumer  empowerment  in  the retail 
market by a legislative anchoring of energy communities, renewable energy communities and 
active customers. Act 469/2023 Coll., which entered into force on 1 January 2024, introduces 
a definition of an energy community and a definition of renewable energy communities. 

While the NECP underlines that a call has been made under the National Recovery Plan to 
support  the  establishment  of  energy  communities  and  an  evaluation  of  energy  community 
projects is ongoing, the plan contains few details on next steps in terms of developing energy 
communities and facilitating citizen engagement.   

Czechia has partially addressed recommendation 15. While the definition of energy poverty 
is  not  yet  legally  enshrined  in  Czech  law,  Czechia  took  steps  to  develop  the  approach  to 
addressing energy poverty. An expert group on energy poverty was set up under the Ministry 
of Industry and Trade. By end of 2024, this expert group was expected to propose a definition 
of  energy  poverty,  set  appropriate  indicators  for  measuring  energy  poverty  and  the  related 
definitions and indicators for vulnerable households. The plan further explains that the expert 

24 Council Directive 2011/70/Euratom of 19 July 2011 establishing a Community framework for the responsible 
and safe management of spent fuel and radioactive waste. 

20 

 
 
 
 
 
 
 
group will aim to continue to coordinate the state’s approach to energy poverty,  develop an 
energy poverty strategy and concrete measures.  

Despite the absence of an energy poverty definition, certain customer support systems (such as 
economic support, protection against disconnection) are in place. The plan explains how the 
use of affordability and energy  efficiency measures already supports vulnerable households 
and can therefore be considered to some extent as addressing energy poverty. In particular, the 
New  Green  Savings  Light  programme  targets  the  elderly  and  low-income  households  and 
provides  funding  for  instance  for  insulation  of  facades,  roofs,  ceilings,  and  exchange  of 
windows.  Subsidies  are  also  available  for  low-income  households  to  replace  old  boilers.  In 
early April 2023, a call was launched with an allocation of CZK 1.7 billion to replace heating 
systems  in  low-income  households.  This  is  expected  to  lead  in  about  15 000  vulnerable 
households changing the way they heat their homes. 

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Czechia has partially addressed recommendation 16. The plan includes a comprehensive 
approach,  although  it  does  not  include  targets  to  support  research,  innovation,  and 
competitiveness  in  clean  energy  technologies,  nor  establishes  a  pathway  to  2030  and  2050. 
Relevant  policies  and  measures  include  the  National  Research  and  Innovation  Strategy  for 
Smart  Specialisation,  the  proposal  for  updating  the  2015  State  Energy  Policy,  the  updated 
National Hydrogen Strategy and the THETA 2 programme supporting applied research and 
innovation in the energy sector. The plan does not set out measures to promote the development 
of  net-zero  projects  including  those  relevant  for  the  energy  intensive  industries.  It  does  not 
describe how it will ensure a predictable and simplified regulatory framework for permitting 
procedures  for  manufacturing  or  how  access  to  national  funding  will  be  simplified  where 
needed. The plan does not include information on policies and measures for the development 
of  clean  energy-related  skills  and  resilient  and  sustainable  supply  chains  of  key  net-zero 
components and equipment.  

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Czechia  has  not  addressed  recommendation  17.  The  plan  does  not  specify  measures  to 
mobilise  private  investments  and  does  not  provide  robust  estimates  of  the  total  investment 
needs  nor  investment  needs  per  sector.  Investment  needs  and  funding  sources  are  not 
mentioned at the level of the measures. There is only a high-level assessment of funding sources 
including national and EU sources. Although the plan states that most of the investments should 
be financed by the private sector, it does not provide a breakdown of investments by public and 
private sources. The information provided in the plan is not sufficient to estimate whether there 
is a potential financing gap with respect to the investment needs, or how this would be filled.  

Czechia has partially addressed the recommendation to provide a robust assessment of 
the  macroeconomic  impact  of  the  planned  policies  and  measures.  A  macro-economic 
assessment is included in the plan, but the analysis of some key variables is absent. The plan 
includes quantitative estimates of the impact on some socio-economic variables and selected 
sectors. However, it does not describe the impact of the planned measures on public finances. 

21 

 
 
 
 
 
2.8  JUST TRANSITION 

Czechia has partially addressed recommendation 20. The plan includes an analysis of the 
social and economic impacts of the transition, providing a comprehensive understanding of the 
potential  effects  on  different  segments  of  the  population.  However,  it  does  not  sufficiently 
address the sectoral employment and skills impacts, except for the coal regions Karlovarský, 
Ústecký and Moravskoslezský. Moreover, the plan does not specify the form of support, the 
impact of initiatives or the resources available, except for the JTF.   

The plan does not contain the analytical basis needed for the preparation of the Social Climate 
Plan, such as information on the estimated impact of ETS2 and the identification of vulnerable 
groups.  The  plan  does  not  explain  how  the  policy  framework  identified  in  the  NECP  will 
contribute to the preparation of Czechia’s Social Climate Plan nor how the consistency of the 
two plans will be ensured. 

2.9  PUBLIC CONSULTATION 

Czechia  has  partially  addressed  recommendation  21.  Czechia  organised  two  rounds  of 
public consultation towards the preparation of the final plan. The first consultation was carried 
out between 15 May 2023 and 4 June 2023 using a structured online unlimited questionnaire 
(164 responses were received). The second consultation on the draft update NECP took place 
between  9  January  and  29  February  2024,  using  a  structured  online  questionnaire  (1092 
responses received).  

The plan includes links to the website of the Ministry of Industry and Trade with a detailed 
summary  and  evaluation  of  both  consultations.  It  does  not  describe  how  the  final  plan 
integrated input from stakeholders. 

2.10 REGIONAL COOPERATION 

Czechia did not address recommendation 22. While the plan includes a simple description 
of how the regional cooperation under the Visegrad group works, it does not specify further 
how it could be strengthened in the future, nor whether Czechia considers joining other regional 
structures such as the CESEC High-Level Group. Czechia does not provide further information 
in its final plan on establishing the framework for cooperation on joint projects by 2025 in line 
with Article 9 of the revised RED II. The plan also did not provide information on signing the 
four bilateral solidarity arrangements for the security of gas supply with its neighbours (Poland, 
Slovakia, Germany, Austria).   

2.11 ANALYTICAL BASIS 

The plan provides a description of the analytical framework with projections reaching 2050 
and an impact assessment of policies and measures. The plan is based on quantitative analysis 
and the methodologies used for projections and impact assessment are referenced. 

22 

 
 
 
 
 
2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

Czechia  has  partially  addressed  recommendation  8.  While  improved,  the  final  updated 
NECP  does  not  sufficiently  cover  the  main  reforms  and  investments  of  the  Recovery  and 
Resilience  Plan  (RRP)  that  contribute  to  implementing  the  objectives,  targets,  and 
contributions. The final updated NECP does not refer to the two reforms LEX RES II and LEX 
RES  III,  which  are  relevant  climate  and  energy  reforms  of  the  RRP  and  its  REPowerEU 
chapter. Some measures, such as the new act on simplification of permitting procedures (LEX 
RES I) and Electricity Data center investment, are now mentioned in the NECP, but it is not 
specified that this reform is financed by the Recovery and Resilience Facility.    

3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

The  Commission  encourages  to  ensure  a  timely  and  complete  implementation  of  the  final 
updated NECP. Czechia should pay particular attention to the elements listed below.  

• 

Implement in a timely manner additional policies towards the ESR target, as even though 
Czechia is expected to meet its target, a significant part of the emissions reduction is driven 
by measures that are not yet fully implemented. Given the stagnating trend in emissions in 
waste  and  transport,  closely  monitor  the  implementation  of  related  policies,  and  design 
additional ones where needed.  

•  On LULUCF, enforce and improve the targeting of current policies, including agroforestry, 
organic  farming,  sustainable  management  of  grassland  and  afforestation  and  closely 
monitor  their  contribution  to  the  achievement  of  the  target. Adopt  additional  policies  to 
decrease the LULUCF gap.   

•  On adaptation, assess quantitatively the relevant climate vulnerabilities and risks for the 
national  objectives,  targets,  contributions,  policies  and  measures  in  the  different  Energy 
Union  dimensions.  This  would  enable  better  outlining  and  quantifying  the  link  to  the 
specific Energy Union objectives and policies, that adaptation policies and measures are 
meant  to  support  as  well  as  setting  out  additional  adaptation  policies  and  measures  in 
sufficient detail. 

•  Develop a roadmap with specific measures to phase out all fossil fuels subsidies.  
•  On  renewable  energy  put  in  place  measures  to  achieve  the  higher  ambition  for  the 
deployment of renewables by 2030 that aligns with the EU’s collective target for renewable 
energy. Accelerate deployment of renewables in district heating and cooling, including by 
creating an enabling framework to integrate electricity and heating and cooling networks. 
Promote the uptake of renewable power purchase agreements and guarantees of origin. 
•  On nuclear energy, continue efforts to diversify nuclear fuel supplies and to ensure long-

term supply of spare parts and maintenance services. 

•  On  energy  efficiency,  further  promote  the  exemplary  role  of  the  public  sector  and  to 
present  additional  measures  to  support  the  achievement  of  end-use  energy  savings 
particularly targeting the industry and transport sectors, where policies  to reduce energy 
consumption appear limited.  

•  On energy poverty, establish the definition of energy poverty in law and create a strategy 
with specific targets, timelines, and concrete measures to support households affected by 

23 

 
 
 
 
 
energy  poverty.  Implement  concrete  measures  including  advice  and  financing  towards 
households in energy poverty. 

•  On  research,  innovation  and  competitiveness,  continue  strengthening  support  to  the 

development and manufacturing of innovative net-zero technologies. 

•  Develop  a  more  comprehensive  just  transition  strategy  that  includes  training  and  re-

skilling measures and that allocates sufficient funding.  

24 

 
 
 
 
 
 
 
Denmark 

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Denmark’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for net 
GHG removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 

Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

31.7% 
(SHARES) 
30.0% 
(target) 

National contribution for 
energy efficiency: 

2022: -23.9% 
2023: -24.9%25 

-50% 

Reported net 
removals of –
0,4 Mt CO2 eq. 
in 2022 

-0,4 Mt CO2 
eq. (additional 
removal 
target) 

2023: 44.4% 

58% (for EU 
42.5% target) 

Primary energy 
consumption  

17.5 Mtoe 

2023: 15.35 
Mtoe 

15.35 Mtoe 

NECP:  
-44.4% 
However, DK is 
expected to meet 
the 2030 target 
with ESR 
flexibilities 

 An 
overachievement 
of -0.23 Mt CO2 
eq compared to 
the 2030 target  

DK contribution 
of 58% is below 
the 60% required 
pursuant the 
formula of Annex 
II of the 
Governance 
Regulation26 

DK primary 
energy 
consumption 
contribution of 
15.35 Mtoe is in 
line with EED 
recast Annex I 
formula results: 
15.52 Mtoe 
(Reference 
Scenario) or 14.67 
Mtoe (Updated 

25  The ESR emissions in 2022 are based on 2024 final GHG inventory reports, and 2023 emissions are based on 
2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as set out 
in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions for 2021-
2025 will only be established in 2027 after a comprehensive review. 
26 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’). 

25 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reference 
Scenario) 

DK final energy 
consumption 
contribution of 
13.73 Mtoe is in 
line with the 
national 
contribution of 
13.73 Mtoe 
submitted by the 
Commission. 

DK has surpassed 
EU-wide 
interconnectivity 
target  

Final energy consumption 

15.20 
Mtoe 

2023: 13.37 
Mtoe 

13.73 Mtoe 

Level of electricity 
interconnectivity (%)27 

51.0% 

2024: 36.0% 

15% 

Source: Eurostat; Denmark’s final updated national energy and climate plan 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In  December  2023,  the  Commission  published  a  thorough  assessment  of  Denmark’s  draft 
updated NECP and provided recommendations28 for the preparation of the final updated NECP. 
Denmark submitted its final updated NECP on 28 June 2024, in line with the deadline of 30 
June 2024.29  

2.1  DECARBONISATION 

Denmark  expects  to  decrease  total  GHG  emissions  (including  LULUCF  and  excluding 
international aviation) by 68% in 2030 compared to 1990. Denmark does not provide emission 
projections for the With Additional Measures (WAM) scenario for 2040 or 2050. 

2.1.1  Effort Sharing Regulation 
Denmark has addressed recommendation 1. The final NECP provides sufficient details on 
how Denmark will meet its ESR target of -50% by 2030 compared to 2005.  

The final plan includes updated projections that mark an improvement compared to the draft, 
showing that Denmark expects to reduce emissions by -44.4% in 2030 compared to 2005, a 
gap of 5.6 percentage points compared to the 2030 target. The plan does not provide a WAM 
scenario  but  explains  that  Denmark  intends  to  close  the  gap  to  the  ESR  target  thanks  to 
additional measures, including an agreed diesel and road tax. Other measures are not outlined 
in the plan.  A decision on the use of ETS and LULUCF flexibilities, or transfers of  annual 
emission  allocations  is  to  be  taken  in  2027  and  2032. In  2023,  GHG  emissions  from  ESR 

27  Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2024). The 2030 level 

represents the general interconnectivity target of 15%.  

28 SWD(2023) 911 final, and Commission Recommendation of 18 December 2023, C/2023/9601. 
29 Article 14(2) of Governance Regulation. 

26 

 
 
 
 
 
 
 
 
 
 
sectors represented 76.4% of the total in Denmark30 (expected be to 90.8% in 2030)31, with 
agriculture projected to represent the largest share (45%).    

The final plan partially complemented the information on some of the measures provided 
in  the  draft  but  could  still  benefit  from  a  clearer  description  of  their  scope,  timeline  and 
expected  greenhouse  gas  reduction  impact.  The  plan  focuses  mainly  on  transport  and 
agriculture.  For  what  concerns  transport,  the  projections  describe  a  drastic  decrease  in 
emissions in the period 2022-2030, with the average percentage decrease per year much larger 
than  in  the  period  2015-2022  (from  -0.55%  to  -4.66%).32 Among  the  measures,  Denmark 
envisaged an increased diesel and road tax, the promotion of electric road transport and the 
deployment of charging stations.  

On  agriculture,  the  government  set  up  a  ‘Green  Tripartite’  to  provide  sector  specific 
recommendations.  An  agreement  has  been  presented  to  reduce  GHG  emissions  by  70%  in 
2030.  The  overall  reduction  gap  compared  to  Denmark’s  commitments  for  2021-2030  is 
estimated  to  reduce  to  around  0.1 million  tonnes  of  CO2  eq.  in  2030.  Measures  to  reduce 
emissions under the ESR are being discussed in the Green Tripartite, including the “Expert 
Group  on  Green  Tax  Reform”  models  for  a  CO2  tax  on  agricultural  inputs.  The  options 
presented  by  the  Expert  Group  are  estimated  to  close  the  remaining  gap  under  the  Effort 
Sharing Regulation.  

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings, road transport and additional sectors (ETS2). The scenario projections account for 
ETS2 but do not clearly quantify its impact in achieving the ESR target. 

2.1.2  LULUCF 
Denmark has addressed recommendation 3. GHG emissions from LULUCF represent 1% 
of the total in Denmark in 2022. The plan includes projections indicating that Denmark will 
deliver additional - 0.44 Mt CO2 eq. of net removals, thus meeting its LULUCF target in 2030. 
The measures proposed within the Tripartite Agreement are commendable, although the effects 
on the LULUCF target have not been quantified. The plan also clarifies the status and progress 
in ensuring higher tier levels and geographically explicit datasets, to ensure the robustness of 
net removal estimates. 

2.1.3  Carbon Capture and Storage 
Denmark has addressed recommendation 2. Denmark’s plans on CCS are comprehensive, 
including a complete political and regulatory framework and competitive financial incentives 
for both capture and storage. The plan contains estimates for total CO2 storage and injection 
capacity and provides split by biogenic and fossil sources. The estimates for CO2 to be captured 
by 2030 are slightly more ambitious than in the draft (15.3 Mt CO2 in the final compared to 
13.7 MtCO2 in the draft).  

2.1.4  Adaptation 
Denmark  has  partially  addressed  recommendation  4.  The  plan  refers  to  the  National 
Climate  Change  Adaptation  Plan  to  respond  to  the  recommendation,  acknowledging  the 

30 Based on EEA data. 
31 Excluding LULUCF.  
32 Compound annual growth rate. 

27 

 
 
 
 
 
 
importance of integrating adaptation planning. It also partially embeds adaptation policies and 
measures in the relevant Energy Union dimensions. 

The plan contains a partial analysis of climate vulnerabilities and risks. It identifies several 
significant risks related to energy security. However, it is short of quantifiable assessment of 
impacts.   

The plan partially outlines the links to the specific Energy Union objectives and policies, 
that adaptation policies and measures are meant to support, particularly for the energy security 
dimension.  Energy  infrastructure  operators  need  to  regularly  prepare  climate  risk  and 
vulnerability  assessments.  The  plan  also  envisages  a  single  digital  entry  point  on  climate 
adaptation information as several actors are responsible for planning and implementing related 
actions.  However,  the  impacts  and  benefits  of  adaptation  policies  on  other  Energy  Union 
objectives  have  generally  not  been  quantified.  Furthermore,  the  resilience  of  the  energy 
systems to structural or seasonal water scarcity is not addressed.  

The plan sets out some additional adaptation policies to support the achievement of national 
objectives, targets and contributions under the Energy Union. It outlines several measures as 
part of the 2023 National Climate Change Adaptation Plan to boost coastal protection, flood 
management,  nature-based  solutions  and  infrastructure  resilience.  The  plan  includes 
afforestation measures in the list of measures potentially considered as nature-based solutions. 
However,  the  description  provides  insufficient  details  to  assess  their  impacts.  Investments 
aimed  at  minimising  environmental  impacts,  such  as  biodiversity  loss  are  considered,  but 
information is missing on whether they contribute to climate change adaptation.  

2.1.5  Fossil Fuels 
Denmark has partially addressed recommendation 19. The plan declares that Denmark does 
not grant direct subsidies to fossil fuels. The Ministry of Taxation is working on a report on 
indirect fossil fuel subsidies. The plan does not clearly indicate remaining fossil fuel subsidies 
nor sets a clear roadmap to phase out33.  

2.2  RENEWABLES  

Denmark has partially addressed recommendation 5. The plan indicates that Denmark’s 
share of renewable energy contributing to the EU target of 42.5% has been set at 58% (and 
60% for the EU target of 45%), which overall are significantly lower than the projection of 
71% for 2030 in the draft updated NECP and lower than the 60% required pursuant the formula 
of  Annex  II  of  the  Governance  Regulation  to  be  in  line  with  the  EU  target  of  42.5%.  The 
updated  trajectory  for  achieving  the  national  contribution  is  provided  including  specific 
reference values for 2025 (of approx. 37%) and for 2027 (of approx. 45%), which are below 
the  trajectory  (43%  and  50%  respectively)  calculated  in  line  with  the  EU  2030  renewable 
energy target of 42.5%. 

Denmark  has  partially  addressed  recommendation  6.  Denmark  provides  estimated 
trajectories for the deployment of renewable energy technologies. Sector-specific projections, 

33 The Commission 2024 study and  Report on Energy subsidies in the EU identifies the existence of fossil fuel 
subsidies. 

28 

 
 
 
 
 
 
including for innovative renewable energy technologies, heating and cooling and renewables 
in  buildings  for  2030  are  included,  but  the  plan  does  not  refer  to  these  as  specific  national 
targets to achieve the sectoral targets of Directive (EU) 2018/2001 (the ‘revised RED II’)34. 
Denmark indicates that it expects to achieve the binding level for RFNBO in industry by 2030. 
Denmark confirms that the renewable energy share in heating and cooling is higher than 60% 
(65% in 2023, expects 80% in 2030) and therefore considers that its annual average increase is 
considered as fulfilled as described under Article 23(2). The plan indicates that Denmark has 
not yet taken a political decision on how to meet the fuel specific minimum requirements in 
2030. However, Denmark indicates that it will comply with the requirements of the revised 
RED II including the target for advanced biofuels and RFNBOs of 1% in 2025 with the national 
CO2  displacement  requirement  and  by  counting  biogas  injected  into  the  Danish  gas  system 
when reporting to Eurostat. The reduction in greenhouse gas intensity in the transport sector is 
estimated to be 27% in 2030.  

Denmark has partially addressed recommendation 7. Denmark generally presents policies 
and  measures  enabling  the  achievement  of  Denmark’s  national  contribution  to  the  EU’s 
binding  renewable  energy  target.  Denmark  explains  that  it  cannot  provide  further  details 
regarding  acceleration  areas  at  this  stage,  as  the  choice  of  technologies  will  depend  on  the 
results  of  the  mapping  exercise  under  Article  15b  of  the  revised  RED  II.  Denmark  has  not 
provided details on the design of the obligation on fuel suppliers in the transport sector.  As 
regards hydrogen, the plan provides information about the invitation to tender for grants for 
the  production  of  Power-to-X  and  don’t  mention  Denmark’s  plans  to  establish  a  hydrogen 
infrastructure for the transport of hydrogen using pipelines in cooperation with Germany.  

Denmark has addressed recommendation 8. The plan provides additional information on 
domestic  supply  of  biomass  per  fuel  type  for  2024-2040  as  well  as  on  different  types  of 
imported  biomass  fuels  for  2022.  It  also  provides  a  description  of  the  sustainability 
requirements for biomass in line with the strengthened sustainability criteria of Article 29 of 
the  revised  RED  II.  In  addition,  it  explains  the  compatibility  of  the  projected  use  of  forest 
biomass  for  energy  production  with  Denmark’s  obligations  under  the  revised  LULUCF 
Regulation, together with national measures and policies to ensure such compatibility. Finally, 
Denmark 
the  sustainable  production  of 
includes 
biomethane/biogas.  

further  measures 

to  promote 

Denmark has partially addressed recommendation 9 as the plan contains insufficient details 
on  the  timeline  and  procedural  steps  related  to  transposition  and  implementation  of  the 
provisions of the revised RED II for most policies and measures. 

2.3  ENERGY EFFICIENCY DIMENSION 

Denmark  has  partially  addressed  recommendation  10.  Denmark  includes  an  indicative 
national contribution of 13.7 Mtoe to the Union’s binding final energy consumption target for 
2030  and  indicative  national  contribution  of  15.4  Mtoe  for  primary  energy  consumption  in 

34 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 

2023/2413  

29 

 
 
 
 
 
 
line35 with Article 4 of Directive (EU) 2023/1791 (‘EED recast’)36.Denmark does not include37 
the amount of energy consumption reduction per year to be achieved by all public bodies nor 
report  the  total  floor  area  of  heated  and  cooled  buildings  owned  by  public  bodies  to  be 
renovated yearly nor the corresponding yearly energy savings to be achieved but opted for the 
alternative  approach.  Denmark  sets  out  policies  and  measures  to  achieve  the  energy 
consumption reduction from public bodies and the renovation of public buildings by applying 
the measure “Energy Efficiency in Government Institution”. This initiative aims to promote 
energy-saving efforts in all public institutions by setting targets. Denmark includes the amount 
of cumulative energy savings of 9.22 Mtoe to be achieved over the period from 2021 to 2030 
with  an  explanation  on  how  the  annual  savings  rate  and  the  calculation  baseline  were 
established. 

Denmark has partially addressed recommendation 11. Denmark set out complete policies 
and measures to achieve the national contributions on energy efficiency, but it did not quantify 
the expected energy savings and the contribution for each of the reported energy efficiency 
measures.  Denmark  did  not  specify 38  how  the  energy  efficiency  first  principle  will  be 
implemented and did not mention any measure to implement it or monitor its implementation. 
Denmark specified robust energy efficiency financing programmes and support schemes and 
specified existing policy measures to promote the uptake of energy efficiency lending products 
and innovative financing schemes (such as On-Bill and On-Tax schemes).  

Denmark has partially addressed recommendation 12. Denmark did not include an updated 
ambition level to ensure a highly energy efficient and decarbonised national building stock and 
to  transform  existing  buildings  into  zero-emission  buildings  by  2050.  Denmark  included 
intermediate milestones for 2030 and 204039. The milestones for the renovation of buildings 
did not include non-residential buildings. Denmark included energy savings milestones for the 
buildings stock. 

Denmark included sufficient information on measures related to buildings in terms of funding 
and costs as well as expected energy savings. Denmark did not include specific information on 
policies and measures addressing deep renovation and the decarbonisation of heating and the 
installation of renewables in buildings.  

2.4  ENERGY SECURITY DIMENSION 

Denmark has partially addressed recommendation 13. In the gas sector, the plan does not 
contain much additional explanation about how concretely Denmark intends to encourage gas 
demand reduction, nor does it develop detailed policies and measures to reach this objective 
towards 2030.  The plan includes a forecast of the evolution of gross inland gas consumption 
which is expected to decrease from 3 962 ktoe in 2022 to 3 127 ktoe in 2030 and 1 396 ktoe in 
2040, as well as for natural gas production which is expected to increase from 1 244 ktoe in 

35  A WAM scenario is not included. 
36 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 
37 Denmark only reported information about the 10% reduction in 2030 compared to 2020 levels to be achieved 

by Danish ministries. 

38 "Denmark  mentioned  that  it  is  in  the  process  of  clarifying  possible  implementation  models  and  awaits  the 

Commission’s guidance in this respect" 
39 They are mentioned as non-binding milestones 

30 

 
 
 
 
 
 
2022 to 3 127 in 2030 and 1 396 in 2040 (WEM scenario). The confirmed objective to have 
Danish biogas production corresponding to 100% of total Danish gas consumption by 2030 is 
positively noted.  

For  electricity,  electricity  storage  comprises  the  main  investment  in  innovative  renewable 
energy sources alongside large heat  pumps  and  Power-to-X plants. The  plan maintains that 
there are no concrete targets for storage capacity but notes an ongoing assessment of the use of 
storage  solutions  for  security  of  electricity  supply  in  the  future.  The  plan  clarifies  that  the 
Electricity Market Regulation will establish targets for non-fossil flexibility, including energy 
storage, once necessary flexibility requirements are determined. 

In the oil sector, the plan contains forecasts on oil consumption until 2050. However, it does 
not sufficiently describe the measures taken to assess the adequacy of the oil infrastructure in 
the long run (refineries, pipeline, oil stocks) with the expected oil demand decline and the move 
to lower-carbon alternatives.  

2.5  INTERNAL ENERGY MARKET DIMENSION 

Denmark has addressed recommendation 14. The plan does not yet set a target for flexibility 
and demand-side response, as this requirement only becomes mandatory in accordance with 
the timeline for the submission of the national report on flexibility needs. Denmark is making 
progress in the promotion of flexibility sources and commits to set a national target by 2027 
based on flexibility needs. The plan also outlines specific planned measures to facilitate system 
integration of renewable energy in accordance with Article 20a of the revised RED II. 

Denmark  has  partially  addressed  recommendation  15.  The  updated  sections  on  energy 
poverty  describe  the  work  done  to  address  energy  poverty  and  gives  a  good  overview  of 
measures currently in place to protect and support both vulnerable consumers and energy poor 
households  in  Denmark. The  updated  document  includes  an  assessment  of  the  households 
affected by energy poverty including a description of the methodology for measuring energy 
poverty  and  provides  an  indicative  number  of  affected  households.  Denmark  considers  that 
energy poverty is well addressed withing social protection policy which includes direct income 
support  as  well  as  structural  measures.  Denmark  does  not  set  a  specific  target  for  reducing 
energy poverty, as their methodology indicates no significant number of households in energy 
poverty.  However,  the  plan’s  assessment  of  number  of  households  in  energy  poverty  is 
significantly lower than indicated by data on energy poverty from EUROSTAT.  

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Denmark  has  partially  addressed  recommendation  16.  The  plan  includes  national 
objectives  in  research,  innovation,  and  competitiveness  to  deploy  clean  technologies, 
establishing a pathway for 2030 with a view to support the decarbonization of industry and 
promote  the  transition  of  businesses  towards  a  net  zero  and  circular  economy.  Significant 
policies and measures include increased investment in Carbon Capture and Storage and Use 
and hydrogen technologies, such as PtX and electrolysers and components throughout the full 
innovation  value  chain  from  research,  development,  maturation,  and  deployment.  The  plan 
refers to measures in the National Strategy for Green Research and Development to promote 

31 

 
 
 
 
 
 
the  development  of  net-zero  projects  including  those  relevant  for  the  energy  intensive 
industries. 

The plan provides measures for the digitalisation of the energy system, promoting flexibility 
solutions  in  electricity  via  data,  sector  coupling  and  a  strategy  (2022-2025)  for  cyber  and 
information security in the electricity, gas, and district heating sectors. 

The plan refers to development of skills but does not convincingly prevent a potential green 
skills  gap,  expecting  measures  and  investments  to  bridge  potential  skills  gaps  and  boost 
entrepreneurship for the energy transition to be supported from the Cohesion Policy Funds. 

The plan does not contain clear national competitiveness targets or measures to facilitate open 
trade for resilient and sustainable supply chains of key net-zero components and equipment. It 
includes measures for regional cooperation in this area and international cooperation is also 
addressed. The plan refers to circular economy measures in policies and research in a general 
way, without providing more detailed actions. 

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Denmark  partially  addressed  recommendation  17.  The  plan  does  not  provide 
comprehensive and consistent estimates of the public and private investment needs in aggregate 
and  by  sector.  The  plan  provides  information  on  agreed  government  funding,  separating 
national and Union sources, and for some measures estimated private funding. However, the 
plan  does  not  outline  how  the  planned  measures  will  mobilise  private  investments.  The 
information  provided in the plan is  not sufficient  to  estimate a potential financing  gap with 
respect to investment needs, and to assess how this would be filled. Moreover, the plan lacks a 
sufficiently developed and robust macroeconomic impact assessment.  

2.8  JUST TRANSITION 

Denmark has partially addressed recommendation 20.  The final updated NECP provides 
limited additional information on the analysis of the social, employment and skills impacts of 
the  transition,  and  other  distributional  impacts  on  vulnerable  groups  as  part  of  the  overall 
macro-economic  assessment  of  the  plan.  The  plan  relies  on  an  environmental  and  climate 
model (the Gron Model) that assess how future economic activities will affect the environment.  
The plan does not include social, re- and up-skilling objectives nor policies for a just transition.   

The plan provides limited information on the impact of the transition to climate neutrality on 
employment, mainly focusing on the results of the Gron Model. Moreover, the plan does not 
specify  the  form  of  support,  the  impact  of  initiatives  or  the  resources  available,  except  for 
ERDF and JTF. The analysis focuses on the JTF and the Territorial Just Transition Plan.  

The plan does not include the analytical basis needed for the preparation of the Social Climate 
Plan  (SCP),  such  as  information  on  the  estimated  impact  of  ETS2  and  the  identification  of 
vulnerable  groups,  apart  from  the  analysis  of  energy  poverty.  Denmark  explains  how  they 
intend to prepare the SCP with the support of the Technical Support Instrument. However, the 
plan does not explain how the policy framework identified in the NECP will contribute to the 
preparation of the SCP, nor how the consistency of the two plans will be ensured.  

32 

 
 
 
 
 
2.9  PUBLIC CONSULTATION 

Denmark has partially addressed recommendation 21. The plan generally describes the fora 
and the ways in which stakeholders were consulted on energy and climate policy, although not 
always referring specifically to the process of preparing the NECP. Denmark organised public 
consultations  for  both  the  draft  and  final  updated  plans  for  periods  of  3  and  4  weeks, 
respectively.  These  consultations  were  mainly  organised  through  an  online  portal,  but  they 
started  very  close  to  the  submission  date,  which  limited  the  possibilities  to  fully  take 
stakeholder  input  into  account  early  in  the  process.  The  plan  includes  a  summary  of  the 
outcome of the consultations and describes how the final plan integrates the inputs and changes 
suggested from stakeholders, including why certain inputs were excluded. 

2.10 REGIONAL COOPERATION 

Denmark  has  addressed  recommendation  22.  It  has  engaged  in  regional  cooperation  by 
being an active member of NSEC and BEMIP, and the plan indicates the work carried out in 
this  context.  Denmark  is  also  working  on  concrete  cross-border  projects  with  neighbouring 
Member States. The plan refers to ongoing negotiations with Poland to sign the last required 
bilateral solidarity agreement for the supply of gas. 

2.11  ANALYTICAL BASIS 

Denmark  has  not  addressed  recommendation  18.  The  final  plan  includes  updated 
projections compared with the draft updated NECP but still does not provide projections under 
the WAM scenario.  

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

The plan covers sufficiently the main reforms and investments of the Recovery and Resilience 
Plan  (RRP)  that  contribute  to  implementing  the  objectives,  targets  and  contributions  of  the 
Energy Union. 

3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

Denmark should swiftly proceed with implementing its final national energy and climate plan. 
Denmark is invited to pay particular attention to the following main elements:  

•  Monitor the impacts of the policies included in the plan on emission reductions under the 
ESR, especially for those not yet included in modelling scenarios. Implement the Green 
Denmark Agreement and quantify its contribution to the ESR and LULUCF targets.  
•  Address gaps in freight transport and modal switch to rail, as Denmark’s rail share of 
9.2%  and  the  electrification  of  the  railway  network  are  below  the  EU  average.  Keep 
momentum in the uptake of electric vehicles and promote electrification of demand. 
•  On adaptation, consider using the recently adopted Climate Adaptation Plan and related 

developments to integrate their priorities in the implementation of the NECP.  

33 

 
 
 
 
 
•  Clarify  fossil  fuel  subsidies  and  set  a  roadmap  and  specific  measures  for  their  gradual 

phase-out. 

•  As regards renewable energy, put in place measures to achieve the higher ambition for 
renewables by 2030 that aligns with the EU’s collective target for renewable energy and 
develop a comprehensive plan for promoting the use of renewable energy in the industry 
sector and to further increase system flexibility, and facilitate the uptake of power purchase 
agreements with specific design measures. 

•  On energy efficiency, develop a clear investment plan that anticipates the investment needs 
for  energy  efficiency  measures,  including  the  private/public  split.  Consider  further 
measures addressing SMEs and smaller enterprises, as only 1.6% of planned energy savings 
from  alternative  measures  under Article  8  EED  recast  are  expected  to  come  from  the 
industry sector, mainly targeting large enterprises.  

•  Denmark is encouraged to refer to Commission Recommendation (EU) 2023/2407 of 20 
October 2023 on energy poverty for a careful balance of indicators to not overlook any 
vulnerable groups. 

•  Regarding  the  internal  energy  market,  establish  a  national  target  for  flexibility  and 

demand-side response, grounded in a thorough assessment of flexibility needs.  

•  Address potential green skills gaps by investing in education and training programs that 
foster  the  development  of  skills  required  for  the  climate  and  energy  transition.  Include 
upskilling  and  reskilling  in  a  comprehensive  just  transition  strategy  which  allocates 
sufficient resources. 

34 

 
 
 
 
 
 
 
 
Germany 

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Germany’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

2022: -18.5% 
2023: -20.9%40 

-50% 

NECP:  
-40.8% 

-3.75 Mt CO2 
eq. (additional 
removal 
target) 

Reported net 
removals of -4.4 
Mt CO2 eq. in 
2022 

19.9% 
(SHARES) 
18% 
(target) 

2023: 21.6% 

41% gross 
final 
consumption 
of energy 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for net 
GHG removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 

Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

National contribution for 
energy efficiency: 

Primary energy 
consumption  

276.6 
Mtoe 

2023: 238.93 
Mtoe 

193.64 
Mtoe 

Insufficient 
ambition based on 
projections: a gap 
of 6.6 Mt CO2 eq 

DE contribution 
of 41% is in line 
with the 
constribution 
according to the 
formula set out in 
Annex II of the 
Governance 
Regulation41. 

DE primary 
energy 
consumption 
contribution of 
193.64 Mtoe is in 
line with the EED 
recast Annex I 
formula results: 
194.23 Mtoe 
(Reference 
Scenario) or 
191.06 Mtoe 
(Updated 
Reference 
Scenario). 

40 
The  ESR emissions  in 2022 are based on  2024  final  GHG inventory  reports, and 2023  emissions are 
based on 2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as 
set out in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions 
for 2021-2025 will only be established in 2027 after a comprehensive review. 
41 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’) 

35 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Final energy consumption 

194.3 
Mtoe 

2023: 187.0 
Mtoe 

155.55 Mtoe 

Level of electricity 
interconnectivity (%)42 

11.4% 

2024: 10.6% 

15% 

Source: Eurostat; Germany’s updated national energy and climate plan 

DE final energy 
consumption 
contribution of 
155.55 Mtoe is in 
line with the 
national 
contribution of 
155.53 Mtoe 
submitted by the 
Commission. 

DE is below the 
EU-wide 
interconnectivity 
target. 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In  December  2023,  the  Commission  published  a  thorough  assessment  of  Germany’s  draft 
updated NECP and provided recommendations43 for the preparation of the final updated NECP. 
Germany submitted its final updated NECP on 28 August 2024, two months after the deadline 
of 30 June 2024.44 

2.1  DECARBONISATION 

Germany confirms its commitment to decreasing total GHG emissions (including LULUCF 
and  excluding  international  aviation)  by  at  least  65%  in  2030  and  at  least  88%  by  2040, 
compared to 1990, as well as its national objective of climate neutrality by 2045.  

2.1.1  Effort Sharing Regulation 
Germany  has  partially  addressed  recommendation  1.  The  final  NECP  does  not  provide 
sufficient details on how Germany will meet its ESR target of -50% by 2030 compared to 2005.  

The plan provides updated projections that mark an improvement compared to the draft plan 
but showing that the existing and planned policies and measures will lead to a decrease of only 
40.8% in 2030 compared to 2005, 9.2 percentage points above the national ESR target.  The 
government is exploring the feasibility of further measures to achieve the target. In 2023, GHG 
emissions from ESR sectors represented 56.9% of the total (63.3% in 2030)45, with transport 
projected  to  represent  the  largest  share.46 The  ‘with  additional  measures’  (WAM)  projected 

42 
Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2024). The 2020 
figure also covers interconnectors with the neighbouring countries outside the EU. The 2030 level represents the 
general interconnectivity target of 15%.  
43 SWD(2023) 928 final, and Commission Recommendation of 18 December 2023, C/2023/9618. 
44 Article 14(2) of Governance Regulation. 
45  The  2023  emissions  are  based  on  2024  approximated  inventory  reports  (Article  26  of  the  Governance 
Regulation). 
46 Based on reporting of greenhouse gas projections (Article 18 of the Governance Regulation). 

36 

 
 
 
 
 
 
 
 
value  in  2030  is  only  1.4%  lower  than  the  projections  under  the  ‘with  existing  measures’ 
(WEM) scenario, hinting  that the plan needs to be complemented  with  impactful  additional 
measures to reach the target. 

The final plan complements the information on the policies and measures provided in the draft 
but more details on scope, timeline and expected impact on GHG emissions would be useful. 
The  plan  focuses  on  cross-sectoral  measures,  covering  all  relevant  sectors.  On  transport, 
Germany provides  a  comprehensive set  of measures based on (modal)  shift and technology 
improvement. However, the specification of new transitory incentives for electric vehicles is 
still pending and the plan includes measures support to fossil-fuelled commercial vehicles.  

On agriculture, the plan provides sufficient detail in terms of funding but not on the impacts 
of measures, and how these contribute to the ESR target. The projections suggest a gradual 
decrease in emissions, although the pace of reduction appears to be relatively slow. 

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings,  road  transport  and  additional  sectors  (ETS2).  The  WEM  and  WAM  scenario 
projections account for the effect of ETS2, however they do not clearly consider the impact of 
ETS2 in achieving the ESR target.  

2.1.2  LULUCF 
Germany  has  partially  addressed  recommendation  3.  The  LULUCF  sector  in  Germany 
generates net removals, absorbing roughly 1% of the total GHG emissions in 2022. According 
to the latest reported 2022 figures, Germany’s performance deteriorated by 9.4 Mt CO2eq in 
comparison to its yearly average in the 2016-2018 reference period. According to the LULUCF 
Regulation, Germany has to enhance its net removals by -3.8 Mt CO2eq in 2030 as compared 
to the reference period. Taking into account its projections for 2030, Germany will still have a 
gap of 6.6 Mt  CO2eq in  2030. The plan indicates that for LULUCF there are no additional 
policies compared to the baseline scenario.  

The plan provides sufficient information on how public funding (CAP, State aid) and private 
financing through carbon farming schemes are used to reach the LULUCF target. The final 
plan does not provide sufficient information on the status and progress in ensuring higher tier 
levels  and  geographically  explicit  datasets  needed  to  ensure  the  robustness  of  net  removal 
estimates. 

2.1.3  Carbon Capture and Storage 
Germany  has  not  addressed  recommendation  2.  Germany’s  NECP  does  not  identify  the 
amount of CO2 emissions that could be captured annually by 2030 and does not provide details 
on how the captured CO2 will be transported. In addition, Germany’s NECP lacks an estimate 
of the total CO2 storage capacity in Germany, and targets on annual injection capacity. Yet, the 
plan adds new actions compared to the draft NECP that are in the process of being implemented 
to further develop a Carbon Management Strategy.  

2.1.4  Adaptation 
Germany has partially addressed recommendation 4. The plan refers to the future national 
adaptation  strategy,  acknowledging  the  importance  of  integrating  adaptation  planning.  It 
nevertheless lacks adaptation policies and measures for most parts of the relevant Energy Union 
dimensions.  The  plan  contains  a  partial  analysis  of  climate  vulnerabilities  and  risks. 

37 

 
 
 
 
 
However, this analysis is restricted to climatic risks for bioenergy and LULUCF and includes 
no quantification.    

The plan partially outlines the links to the specific Energy Union objectives and policies, 
that adaptation policies and measures are meant to support. It identifies droughts and calamities 
as threats to bioenergy and LULUCF objectives and refers to planned and implemented nature-
based solutions in forestry and urban areas. However, the mentioned impacts and benefits of 
nature-based solutions have generally not been quantified, and there is no information on other 
Energy  Union  objectives  and  policies  that  adaptation  policies  and  measures  are  meant  to 
support. The plan does not set out significant additional adaptation policies and measures 
to support the achievement of national objectives, targets and contributions under the Energy 
Union.  The  description  of  the  forestry  and  urban  greening  measures  provides  insufficient 
details  to  assess  their  scope,  timing  and  expected  effects  on  the  Energy  Union  dimensions. 
Beyond these two sectors, specific descriptions of measures in other areas are missing. 

2.1.5  Fossil Fuels 
Germany  has  partially  addressed  recommendation  19.  The  plan  includes  a  timeline  to 
phase-down fossil fuels for energy use by 2038 at the latest. It also mentions the need to phase 
out fossil fuel subsidies, referring to G20 and G7 commitments to eliminate inefficient fossil 
subsidies by 2025, but does not provide a precise timeline. The plan only states that Germany 
will conduct more intensive and regular reviews of subsidies, particularly with respect to their 
climate impact. Moreover, the plan indicates that Germany will establish a unified framework 
for defining climate-damaging subsidies but does not provide a clear explanation of how this 
framework will be implemented or what specific measures will be taken to phase out fossil fuel 
subsidies. 

2.2  RENEWABLES  

Germany has partially addressed recommendation 5.  Germany raised the ambition from 
40% in the draft NECP to a share of renewable energy sources of at least 41% in line with 
the formula in Annex II of Governance Regulation, as a contribution to the Union’s binding 
renewable energy target for 2030 laid down in Article 3(1) of Directive (EU) 2018/2001 (the 
‘revised RED II’)47. However, the plan does not provide reference points for 2025 and 2027 
for this increased contribution. WEM and WAM scenarios with data for 2025 and 2027 are 
provided but no scenario reaches 41%, the highest being 38.2% (WAM, assuming all consumed 
hydrogen to be renewable). 

Germany has partially addressed recommendation 6. It provides an estimated trajectory for 
all  renewable  technologies  and  a  long-term  plan  for  the  deployment  of  renewable  energy 
technologies for key technologies in electricity (PV, onshore, offshore wind, and biomass) over 
the next 10 years, with an outlook to 2040. The final plan also contains projections for 2030 
for large industrial heat pumps (above 500 kW) to reach 2.1 GW electric and 6.3 GW thermal 
capacity and for district heat pumps (below 500 kW) to reach 57.6 GW thermal capacity. 

47 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  

38 

 
 
 
 
 
 
 
Germany does not include an indicative target for innovative renewable energy technologies 
by 2030 in line with the revised RED II. However, Germany has set an indicative renewables 
target for industry, in line with the revised RED II but does not include a binding minimum 
share of RFNBOs in industry by 2030. Germany has moreover confirmed its transport target 
of 30%, 1 percentage point higher than the target of the revised RED II (all scenarios are well 
above than the 30%). Germany has not included a specific target to contribute to the indicative 
sub-target in buildings for 2030 but a range of 46-50%, stating that they are awaiting a guidance 
on the calculation method before being able to provide a final indicative target. Germany has 
confirmed that projections included in the draft plan are contributing to the binding targets in 
heating and cooling for both 2021-2025 and 2026-2030, and the indicative target to achieve 
the top-ups of Annex IA of the revised RED II. The indicative contribution including the top-
ups is however  0.5 percentage points  higher than the confirmed contributions for 2025 and 
2030 (i.e. 23.5% instead of 23% and 32.5% instead of 32% for 2025 and 2030 respectively). 
Germany  announced  that  it  will  increase  the  level  of  ambition  for  advanced  biofuels  and 
renewable  fuels  of  non-biological  origin  (RFNBOs)  in  the  transport  sector  in  line  with  the 
revised targets set out in RED.   

Germany has partially addressed recommendation 7. Germany includes in its final NECP 
some additional information on policies and measures, updating it with additional measures 
taken since adoption of the draft NECP update. Germany does not detail for which technologies 
it would designate renewables acceleration areas but mentions several policies and measures 
that  aim  at  speeding  up  renewables  deployment.  In  particular  for  the  development  of  wind 
energy is raised, e.g. the obligation for the regions to designate a certain percentage of their 
territory as specific onshore wind areas. 

Germany does not describe how it aims to accelerate the deployment of renewables via the 
uptake  of  renewable  power  purchase  agreements,  guarantees  of  origin  and  an  enabling 
framework  to  promote  self-consumption.  The  final  updated  plan  specifies  a  detailed  list  of 
measures for the acceleration of the deployment of renewables and the phasing out of fossil 
fuels in the heating and cooling sector but does not detail to what extent the different elements 
will  contribute  to  the  higher  renewables  share  in  heating  and  cooling.  The  plan  includes 
information on different policies and measures for sector integration, where electrification of 
transport and heating, combined with a strong increase in storage capacities and digitalisation, 
will play a decisive role. Germany will update the obligation on fuel suppliers (THG quota) in 
the transport sector to achieve a sub-target for advanced biofuels and renewable fuels of non-
biological  origin  (RFNBOs)  in  the  transport  sector  and  set  out  measures  for  promoting 
hydrogen in industry. 

Germany  has  partially  addressed  recommendation  8.  The  plan  lacks  details  on  the 
procedural steps and timelines for most policies and measures. The plan does not include a full 
assessment of the domestic supply of forest biomass for energy purposes in 2021-2030 in 
accordance  with  the  strengthened  sustainability  criteria  of  the  revised  RED  II  nor  does  it 
include an assessment of the compatibility of the projected use of forest biomass for energy 
production with Germany’s obligations under the revised LULUCF Regulation, particularly 
for 2026-2030, together with national measures and policies to ensure such compatibility.  In 
addition,  Germany  includes  specific  measures  to  promote  the  sustainable  production  of 
biomethane/biogas but without stating a clear target. 

39 

 
 
 
 
 
Germany has not addressed recommendation 9 by providing an expected timeline of the 
steps leading to the adoption of legislative and non-legislative policies and measures aimed at 
transposing and implementing the provisions of the revised RED II. 

2.3  ENERGY EFFICIENCY DIMENSION 

Germany  has  partially  addressed  recommendation  10.  The  plan  includes  an  indicative 
national contribution for 2030 of 155.5 Mtoe for final energy consumption in line with Article 
4  of  Directive  (EU)  2023/1791  (‘EED  recast’)4849 Germany  includes  the  amount  of  energy 
consumption reduction per year to be achieved by all public bodies50 nor report the total floor 
area of heated and cooled buildings owned by public bodies to be renovated yearly  - or the 
corresponding  yearly  energy  savings  to  be  achieved,  but  it  specified  that  it  opted  for  the 
alternative approach.  

Germany has partially addressed recommendation 11. Germany sets out complete policies 
and measures to achieve the national contributions on energy efficiency, but it does not quantify 
the expected energy savings and the contribution for each of the reported energy efficiency 
measures.  Furthermore,  it  is  specified  how  the  energy  efficiency  first  principle  will  be 
implemented.  The  plan  sets  out  some  energy  efficiency  financing  programmes  and  support 
schemes,  including  financial  instruments  and  public  guarantees,  able  to  mobilise  private 
investments  and  additional  co-financing.  Germany  specifies  existing  policy  measures  to 
promote the uptake of energy efficiency lending products and innovative financing schemes 
sand  established  a  National  Energy  Efficiency  Fund,  but  it  did  not  detail  the  role  of  and 
provided sufficient information on the fund.  

Germany has not addressed recommendation 12. Germany did not update its milestones in 
comparison with the 2020 Long Term Renovation Strategy 2. The final NECP explains that it 
does not revise the national LTRS as part of the plan but only provides an update on policy 
measures.  The  final  updated  NECP  recalls  the  intermediate  milestone  of  primary  energy 
consumption to be achieved in 2030, but the milestones for 2040 and 2050 are missing. The 
building sector is targeted throughout several sections of the NECP, through financing schemes 
and regulations. Measures on buildings are expected to generate significant energy savings, 
however the NECP does not sufficiently describe the link between renovation rates and energy 
savings, nor between measures and financing. 

2.4  ENERGY SECURITY DIMENSION 

Germany has partially addressed recommendation 13. On gas, the final updated plan does 
not  define  clear  objectives  for  diversifying  energy  sources  or  for  further  encouraging  gas 
demand  reduction  towards  2030.  The  final  plan  does  provide  a  more  ambitious  forecast  of 
fossil gas consumption than the draft, with a decrease from 2,813 PJ in 2024 to 2,513 PJ in 
2030, 1,143 PJ in 2040 and 868 PJ in 2050. 

48 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 
49 However, the WAM scenario 2030 projection (186.7 Mtoe) is not in line with the target. 
50 An annual consumption reduction target of 2% is given without specifying the savings impact in terms of Mtoe. 
However, the baseline is equal to 68.9 TWh, so the absolute reduction for the first year could be calculated as 
equal to 1.4 TWh (120 ktoe). 

40 

 
 
 
 
 
 
On  electricity,  the  final  plan  includes  additional  measures  to  enhance  system  flexibility, 
including smart grids, demand response, and storage strategies, such as the electricity storage 
strategy  introduced  in  December  2023.  However,  there  are  few  specific  timelines  for 
implementation and cross-border cooperation to address structural grid congestion. 

The  plan  contains  projections  on  oil  consumption  until  2050.  It  is  positively  noted  that 
Germany  identifies  the  need  to  ensure  security  of  oil  supply  in  the  context  of  electrifying 
transport. However, the plan does not describe in detail the measures taken to assess the long-
term adequacy of the oil infrastructure (refineries, pipeline, oil stocks) with the expected oil 
demand decline and the move to lower-carbon alternatives. 

The final plan refers to the new federal adaptation law and the development of a new national 
adaptation strategy. However, it does not clearly put forward policies and measures to  integrate 
the imperative of climate adaptation in the energy system  

2.5  INTERNAL ENERGY MARKET DIMENSION 

Germany  has  partially  addressed  recommendation  14.  The  plan  acknowledges  the 
importance of flexibility of the energy system against the background of an increasing share 
renewable electricity production, lists existing, planned, and other possible measures as well 
as reports about an ongoing stakeholder consultation process on the reform of electricity market 
related national rules. However, the plan does not put forward clear objectives and targets for 
demand response or other options to improve the flexibility of the energy system. Instead, it 
refers to the planned definition of an indicative national objective for non-fossil flexibility.  

As regards empowering consumers, the plan provided explanations to the roll out of smart 
meters and their promotion, including through digital solutions, to advisory services provided 
to  consumers,  and  description  of  the  protection  of  consumers.  While  some  information  is 
provided on the regulatory framework for energy communities, further explanations to how to 
actively  empower  citizens  to  participate  on  the  energy  market  through  energy  sharing, 
collective purchasing or self-consumption are missing. 

The  plan  does  not  include  a  timetable  with  appropriate  measures  to  remove  structural 
congestion  in  the  electricity  system  and  to  provide  efficient  dispatch  and  location  signals. 
Instead, it refers to the action plan notified in 2019 (“Aktionsplan Gebotszone”). Germany also 
reports that more electricity transmission capacities will be needed, and that more congestion 
can be expected at least until planned large HVDC transmission lines will be completed, which 
could indicate that the Action Plan of 2019 may no longer be up to date. 

Germany  has  partially  addressed  recommendation  15.  While  there  are  sufficient 
explanations as to how the social security systems help affordability (e.g. through improving 
the housing benefits or improving the legislative environment to prevent disconnections from 
electricity and gas), the final plan lacks both a thorough assessment of people in energy poverty 
and  a  measurable  reduction  target  and  to  that  connected  share  of  savings  to  be  achieved  in 
households  affected  by  energy  poverty.  Germany  has  many  structural  energy  efficiency, 
building renovation, decarbonisation, renewable energy and heating and cooling measures that 
are  implemented  in  residential  buildings  and  a  few  of  them  are  specifically  addressing 
vulnerable  households  (such  as  the  support  for  the  exchange  of  heating  based  on  income, 
support for subsidised supplementary loan for restructuring measures in dwellings of people 

41 

 
 
 
 
 
 
with taxable household income up to EUR 90,000 per year, the EEG surcharge and targeted 
advisory and knowledge support to vulnerable people on energy savings or energy efficiency 
measures and regulates the allocation of CO2 costs between tenants and landlords).  

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Germany has partially addressed recommendation 16. The plan includes a comprehensive 
approach, including targets and measures to support research, innovation and investments in 
clean energy technologies, the manufacturing of clean energy technologies and equipment, and 
the  digitalisation  of  the  energy  value  chain.  Significant  policies  and  measures,  including 
Germany’s  7th  Energy  Research  Programme  or  specific  programmes  to  support  research, 
innovation and the competitiveness of net-zero technologies (e.g. hydrogen or CCUS) are being 
presented. The plan includes information about the measures but does not include a specific 
breakdown of investment in research and innovation (R&I) for the energy sector for 2030 and 
beyond. Similarly, it presents the implications of the Net-zero Industry Act for Germany but 
lacks clear competitiveness targets and measures for regional cooperation in this area.  

The plan does not provide details on policies and measures for the digitalisation of the energy 
system. The plan does set out some measures for net-zero projects, but it provides only limited 
information  on  projects  relevant  for  energy  intensive  industries.    The  plan  does  not  fully 
describe how the measures will ensure a predictable and simplified regulatory framework for 
permitting procedures for manufacturing and how access to national funding will be simplified 
where needed. It provides no detailed policies and measures to facilitate open trade for resilient 
and sustainable supply chains of key net-zero components and equipment. The plan includes 
information  on  measures  and  investments  to  bridge  potential  skills  gaps  for  the  energy 
transition. 

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Germany partially addressed recommendation 17. The assessment of the overall additional 
investments needed to reach the energy and climate targets is based on the top-down model 
used for the WEM and WAM scenarios. The plan discusses financial instruments to mobilise 
more private capital for the energy transition but does not provide a comprehensive breakdown 
of  investment  needs,  focusing  only  on  sector-specific  studies.  The  plan  does  not  quantify 
funding sources and does not link them to specific investment needs. The information provided 
in the plan is not sufficient to estimate whether there is a potential financing gap, or how this 
would be filled. 

2.8  JUST TRANSITION 

Germany has partially addressed recommendation 21.  The plan provides some information 
on  the  impact  of  the  transition  to  climate  neutrality  on  employment  and skills  but  does  not 
sufficiently describe the impact on vulnerable households. Moreover, the plan mentions that 
EUR 40 billion are provided from national funds in support to federal states affected by the 
coal phase-out. The analysis focuses on the JTF, and the Territorial Just Transition Plan.  

The plan lacks the analytical basis needed for the preparation of the Social Climate Plan, such 
as information on the estimated impact of ETS2 and the identification of vulnerable groups. 

42 

 
 
 
 
 
While  acknowledging  the  need  for  coherence,  the  plan  does  not  explain  how  the  policy 
framework  identified  in  the  NECP  will  contribute  to  the  preparation  of  Germany’s  Social 
Climate Plan nor how the consistency of the two plans will be ensured. It refers to the existing 
CO2  taxation  at  national  level  having  similar  impacts  as  ETS2,  and  to  the  mitigating/social 
fairness measures in place.  

2.9  PUBLIC CONSULTATION 

Germany  has  partially  addressed  recommendation  22.  The  plan  generally  describes  the 
ways  in  which  stakeholders  were  consulted.  However,  the  process  was  not  specific  to  the 
NECP, but rather on the related energy and climate policies and measures. The consultations 
were  organised  with  targeted  stakeholders,  through  dialogues,  roundtables,  platforms,  and 
networks.  

Only after the submission to the European Commission and the publication of the draft NECP, 
a limited online consultation was held between 24 January 2024 and 17 March 2024 on the 
adequacy of objectives and measures. The plan includes a general summary per dimension of 
the  comments  received  during  the  consultation  on  the  draft  NECP.  However,  it  does  not 
describe how the final plan integrated the inputs and changes suggested from stakeholders. 

2.10 REGIONAL COOPERATION 

Germany has partially addressed recommendation 23.  The plan includes information on 
several  joint  projects  to  produce  renewables  energy,  especially  in  the  offshore  wind  area. 
However, the final updated plan does not refer to any progress as regards the signature of the 
remaining  bilateral  solidarity  agreements  for  the  security  of  gas  supply  (Poland,  Czechia, 
France, Luxembourg, Belgium, and the Netherlands), nor does it refer to the signature of an 
agreement with Italy in March 2024.  

2.11 ANALYTICAL BASIS 

Germany has addressed recommendation 20. The plan is based on an updated modelling 
exercise, which now includes a WAM scenario. The methodologies and models used are not 
described in detail, but the NECP references documents that describe them, with projections 
reaching 2050. However, some of them are not publicly available yet.  

The draft NECP also provides an impact assessment of policies and measures, which includes 
a macro-economic assessment and partial assessment of social and health impacts. 

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

Germany partially addressed recommendation 18. The final updated covers sufficiently the 
main reforms and investments of the Recovery and Resilience Plan (RRP) that contribute to 
implementing the objectives, targets and contributions of the Energy Union. The final updated 
NECP  still  does  not  refer  to  the  investments  related  to  the  support  programme  for  the 
development of a climate-friendly timber construction and to the municipal living labs for the 
energy transition, which are relevant climate and energy reforms and investments of the RRP 

43 

 
 
 
 
 
and its REPowerEU chapter. The final updated NECP includes the following investments and 
reforms  without  linking  them  to  the  RRP  and  the  REPowerEU  chapter:  energy  efficiency 
measures in buildings, investments in efficient heat networks, investments in the promotion of 
industries involved in hydrogen and fuel cell applications for transport, and reforms promoting 
the acceleration of wind energy, onshore and offshore.  

3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

The Commission encourages Germany to ensure a timely and complete implementation of the 
final updated NECP. Germany is invited pay particular attention to the following elements:  

•  On  ESR,  closely  monitor  the  impacts  of  the  policies  included  in  the  plan  and  increase 
efforts  to  reduce  GHG  emissions  across  all  effort  sharing  sectors.  Explore  possible 
available flexibilities to ensure compliance with the ESR obligations.  

•  On LULUCF, strengthen measures to enhance removals to meet the 2030 target. Consider 
scaling up climate-adapted forest management with long-term financial support to drive 
innovation  in  carbon  sequestration  and  accelerating  reforestation  and  afforestation  with 
strict  monitoring  to  ensure  net  carbon  gains.  Strengthen  the  cascade  use  principle  to 
maximise  carbon  storage  in  harvested  wood  products.  Ensure  bioenergy  policies  are 
aligned  with  sustainability  criteria  to  avoid  carbon  losses.  Expand  private  financing 
through carbon credit markets and fully implementing Tier-3 monitoring. 

•  On  adaptation,  consider  using  ongoing  adaptation  policy  processes,  such  as  the 
preparation  of  the  next  adaptation  strategy,  to  further  assess  quantitatively  climate 
vulnerabilities  and  risks  for  the  achievement  of  the  national  objectives,  targets  and 
contributions, and the policies and measures in the Energy Union dimensions,  That would 
enable better outlining and quantifying the link to the Energy Union objectives and policies 
that adaptation policies and measures are meant to support, as well as setting out additional 
adaptation policies and measures in sufficient detail.     

•  Map fossil fuel subsidies, including those in the transport sector, and develop a roadmap 

• 

for their phase-out. 
In terms of renewable energy, establish reference points for 2025 and 2027 for the share 
of renewable energy sources and determine an RFNBO target in industry. 

•  Assess  further  measures  to  decrease  energy  consumption  of  transport  sector.  Raise 
ambition of transport policies, e.g. by incentivising use of public transport, incentives for 
electric vehicles and by significantly improving rail infrastructure.  

•  On  energy  efficiency,  put  it  place  additional  financing  instruments  to  support  energy 

efficiency investment needs.  

•  On  industry,  design  actions  to  reduce  energy  costs,  address  structural  congestion  and 
assess  further  measures  to  decrease  energy  consumption,  such  as  increasing  the  use  of 
energy  management  systems  and  exploiting  heating  and  cooling  potential.  Swiftly 
implement the Carbon Management Strategy for the deployment of CCUS technologies. 
•  As regards buildings, ensure stability of renovation funding programs and further promote 
the electrification of heating by addressing the unbalanced electricity-to-gas-price ratio.  

44 

 
 
 
 
 
• 

Identify people in energy poverty through a set of indicators following EU legislation to 
better direct the structural measures towards vulnerable people and to improve the energy 
efficiency and decarbonisation of the housing stock for the most vulnerable groups.  
•  Set  a  concrete  timetable  and  specific  actions  to  address  structural  congestion  in  the 

electricity grid.  

45 

 
 
 
 
 
 
 
Ireland 

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Ireland’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

2022: -3.8% 
2023: -10.3%51 

-42% 

NECP:  
-25.4% 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for net 
GHG removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 

Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

National contribution for 
energy efficiency: 

Reported net 
emissions of 
7.34 MtCO2 eq. 
in 2022,  

-0.63 Mt CO2 
eq. (additional 
removal 
target) 

16.2% 
(SHARES) 
16% 
(target) 

2023: 15.3% 

43% 

Primary energy 
consumption  

13.9 Mtoe 

2023: 14.06 
Mtoe 

11.29 Mtoe 

Insufficient 
ambition based on 
projections: a gap 
of 1.36 Mt CO2 
eq compared to 
the 2030 target 

Ireland’s 
contribution of 
43% is in line the 
level required 
according to the 
formula set out in 
Annex II of the 
Governance 
Regulation52 

IE primary energy 
consumption 
contribution of  
11.29 Mtoe is in 
line with the EED 
recast Annex I 
formula results: 
11.23 Mtoe 
(Reference 
Scenario) or 11.29 
Mtoe (Updated 
Reference 
Scenario). 

51  The ESR emissions in 2022 are based on 2024 final GHG inventory reports, and 2023 emissions are based on 
2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as set out 
in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions for 2021-
2025 will only be established in 2027 after a comprehensive review. 
52 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’). 

46 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
Final energy consumption 

11.7 Mtoe 

2023: 12.0 Mtoe 

10.45 Mtoe 

Level of electricity 
interconnectivity (%)53 

6.6% 

2024: 0% 

15% 

Source: Eurostat; Ireland’s updated national energy and climate plan 

IE final energy 
consumption 
contribution of 
10.45 Mtoe is in 
line with the 
national 
contribution of 
10.45 Mtoe 
submitted by the 
Commission. 

IE is below the 
EU-wide 
interconnectivity 
target. 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In February 2024, the Commission published a thorough assessment of Ireland’s draft updated 
NECP and provided recommendations54 for the preparation of the final updated NECP. Ireland 
submitted its final updated NECP on 22 July 2024, a few weeks after the deadline of 30 June 
2024.55 

2.1  DECARBONISATION  

Ireland  expects  to  decrease  total  GHG  emissions  (including  LULUCF  and  excluding 
international aviation) by 20% in 2030, by 33% in 2040 and by 36% in 2050, as compared to 
1990. Ireland committed to reach climate-neutrality by 2050 in the Climate Action and Low 
Carbon Development Act.  

2.1.1  Effort Sharing Regulation 
Ireland has partially addressed  recommendation 1. The plan does  not provide sufficient 
information on how Ireland will work to meet its ESR target of -42% by 2030 compared to 
2005. 

The  plan  provides  updated  projections  showing  that  the  existing  and  planned  policies  and 
measures  will  lead  to  a  decrease  of  only  25.4%  in  2030  compared  to  2005,  a  gap  of  16.6 
percentage points from the national ESR target. However, the plan explains that some policies 
are not yet modelled in the projections. In 2023, GHG emissions from ESR sectors in Ireland 
represented around 78% of the total (expected to be 83% in 2030)56 , with agriculture projected 
to represent the largest share. The ‘with additional measures’ (WAM) value in 2030 is about 

53   Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2024). The 2020 figure 
also covers interconnectors with the neighbouring countries outside the EU. The 2030 level represents the general 
interconnectivity target of 15%.  
54 SWD(2024) 42 final, and Commission Recommendation of 23 February 2024, C/2024/1187. 
55 Article 14(2) of Governance Regulation. 
56 The 2023 emissions are based on 2024 approximated inventory reports. 

47 

 
 
 
 
 
 
 
 
 
18% lower than the ‘with existing measures’ (WEM) scenario, hinting that implementing the 
plan will require a significant effort. Ireland states that ETS and LULUCF flexibilities will not 
be enough to  bridge  the  gap to  target. The final  plan complemented the information  on the 
policies and measures provided in the draft but more details on scope, timeline and expected 
impact on GHG emissions would be useful.  

The plan sets out a large array of additional measures in the agricultural sector. However, key 
to delivering is the provision of low emission animal feeds and low emission fertilisers, many 
of which are still in early development. Moreover, incentives are needed for their uptake. The 
plan acknowledges the absence of more wide-ranging measures that could deliver substantial 
emission  reductions,  such  as  diversification  into  less  carbon  intensive  agriculture  and  a 
reduction of the large number of (dairy) herds. 

On transport, the plan sets out measures to have all new cars zero carbon emission or zero 
emission-capable by 2030, with a longer-term goal to decarbonise the passenger car fleet by 
2050.  

F-gas  emissions  are  projected  to  increase  from  2030  to  2050  probably  due  to  Ireland’s 
semiconductor sector. This is concerning given their high global warming potential.  

Ireland has notified the use of a derogation not to apply the carbon pricing under the emissions 
trading system for fuel combustion in buildings, road transport and additional sectors (ETS2) 
until the end of 2030. The plan provides information on the national carbon tax and refers to 
ETS2.  The scenario projections  account  for the effect of the national  carbon tax  but  do not 
clearly quantify its impact in achieving the ESR target. 

2.1.2  LULUCF 
Ireland  has  partially  addressed  recommendation  3.  The  LULUCF  sector  in  Ireland 
generates emissions, representing 7% of the total GHG emissions in Ireland in 2022. There is 
a significant overlap between agriculture and the LULUCF sector as the vast majority of land 
is agricultural land. Thus, land use emissions and removals are strongly influenced by actions 
undertaken by farmers. According to the LULUCF Regulation, Ireland has to enhance its net 
removals  by  -0.63  MtCO2eq  in  2030  compared  to  the  yearly  average  in  the  2016-2018 
reference period. According to 2022 figures, Ireland has improved its performance by  -1.62 
MtCO2eq  compared  to  the  reference  period.  Nevertheless,  even  considering  numerous 
additional measures, Ireland still expects a gap of 1.36 Mt CO2eq in 2030. 

The plan clearly acknowledges the need for both public (CAP, State aid) and private finance 
to  achieve  Ireland’s  LULUCF  targets  and  details  the  financial  commitment  for  individual 
measures.  On  agricultural  measures,  the  plan  provides  specific  quantification  of  how  these 
policies contribute to emission reductions.  

However, the plan lacks sufficient information on the status and progress in ensuring higher 
tier levels and geographically explicit datasets needed to ensure the robustness of net removal 
estimates. 
2.1.3  Carbon Capture and Storage 
Ireland  has  not  addressed  recommendation  2.  The  plan  does  not  provide  a  strategy  on 
CCUS. However, the plan recognises the potential of the technology to support the transition 
to a low carbon economy. Ireland adopted a 5-year CCS review process, which will inform any 
decision to commit resources and put regulatory and permitting systems in place. 

48 

 
 
 
 
 
2.1.4  Adaptation 
Ireland  has  partially  addressed  recommendation  4.  The  plan  refers  to  the  National 
Adaptation  Framework  (NAF),  acknowledging  the  importance  of  integrating  adaptation 
planning.  It  is  rather  comprehensive  and  embeds  adaptation  policies  and  measures  in  the 
relevant Energy Union dimensions. However, the plan lacks detail in their scope and timeline 
needed for an estimation of their impact.  

The  plan  includes  a  thorough  analysis  of  climate  vulnerabilities,  and  identifies  several 
significant risks related to flooding, droughts, winds and storms, and fluctuations in wind and 
solar  energy.  However,  except  for  the  cost  of  flood  defenses,  it  is  short  of  quantifiable 
assessment of impacts. The plan outlines the links to specific Energy Union objectives and 
policies that adaptation policies and measures are meant to support. The plan informs about a 
new sectoral climate change risk assessment to be finalised in 2025. However, the impacts and 
benefits  of  adaptation  policies  on  the  Energy  Union  objectives  have  generally  not  been 
quantified.  

The plan does not set out significant additional adaptation policies and measures to support 
the achievement of national objectives, targets and contributions under the Energy Union.    

2.1.5  Fossil Fuels 
Ireland has partially addressed recommendation 19. The plan indicates that peat and coal 
are expected to no longer be part of the electricity generation mix post 2025. Ireland has also 
committed  to  explore  the  potential  for  carbon  capture  and  storage  (CCS)  technology  at  the 
Money Point power plant.  

The plan describes different types of fossil fuel subsidies but lacks detailed measures and  a 
timeline  for  phasing  them  out.  Moreover,  Ireland  carried  out  a  review  of  the  main  existing 
fossil fuel tax subsidies, mainly the diesel excise gap, and a diesel rebate scheme, and identified 
options for their phase-out  

2.2  RENEWABLES  

Ireland addressed recommendation 5. Ireland raised its contribution of renewable energy in 
final energy consumption from 31.4% in the draft NECP to 43% for 2030 based on the WAM 
scenario. The increased contribution corresponds to the level calculated in line with the formula 
of Annex II of the Governance Regulation. The final NECP also includes an updated indicative 
trajectory to reach the 43% in 2030 including the specific reference points for 2025 (20.3) and 
for  2027  (25.9);  however,  those  values  are  below  the  trajectory  calculated  in  line  with  the 
increased EU renewable energy target of 42.5% (28% and 33% respectively). Ireland explains 
that it is mainly due to the longer timeframe needed for building large wind energy and district 
heating projects which will be operational by the end of this decade57. 

Ireland partially addressed  recommendation 6. The final NECP includes projections and 
trajectories for renewable technologies and trajectories for renewables in heating and cooling, 
industry, and transport for 2030. However, it does not include a specific target for buildings, 

57 The RES share is projected to increase steeply from  34.9% in 2029 to 42.7% in 2030 due to the large RES 
projects becoming operational. 

49 

 
 
 
 
 
 
district  heating  and  cooling,  a  minimum  level  of  RFNBO  for  industry  in  2030.  As  regards 
innovative renewable energy sources, Ireland does not set a specific target in its plan but states 
that  this  challenge  will  be  addressed  through  different  policy  instruments.  The  heating  and 
cooling target is above the binding level of Directive (EU) 2018/2001 (the ‘revised RED II’)58. 
The NECP indicates that the transport target will be met with an energy-based obligation that 
includes a minimum share for advanced biofuels.  A minimum share for RFNBOs in transport 
will be set via national legislation.   

Ireland has partially addressed recommendations 7 and 9. The final NECP provides some 
additional information on policies and measures to achieve Ireland’s national contribution to 
the Union’s renewable energy target. It describes in detail the progress made on the acceleration 
of  permitting.  However,  it  does  not  describe  how  Ireland  plans  to  designate  “renewable 
acceleration areas”. It gives indications on how Ireland aims to increase the integration between 
electricity and heat but insufficiently describes plans to recover and use waste heat. The final 
NECP lacks details on the procedural steps and timelines for most policies and measures. 

Ireland has addressed recommendation 8. The final NECP provides estimated trajectories 
for  biomass  supply  by  feedstock  for  both  domestic  production  and  imports  as  well  as  for 
bioenergy demand by feedstock. It includes national measures to ensure the compatibility of 
forest biomass use with the RED sustainability criteria and with Ireland’s obligations under the 
revised  LULUCF  Regulation.  Ireland  also  provides  explanations  on  how  to  ensure  the 
compatibility  of  afforestation  measures,  the  projected  increase  of  use  of  solid  biomass  for 
energy, LULUCF sinks and biodiversity. Finally, Ireland includes further measures to promote 
the sustainable production of biogas/biomethane and digestate.  

2.3  ENERGY EFFICIENCY DIMENSION 

Ireland has partially addressed recommendation 10. Ireland includes an indicative national 
contribution of 10.45 Mtoe to the Union’s binding final energy consumption target and 11.29 
Mtoe to the Union’s indicative primary energy consumption target and for 2030 in line with 
Article 4 of Directive (EU) 2023/1791 (‘EED recast’)59. However, Ireland does not include the 
amount  of  energy  consumption  reduction  per  year  to  be  achieved  by  all  public  bodies  as 
required by Article 5 of EED Recast. Ireland does not include the amount of cumulative energy 
savings to be achieved over the period from 1 January 2021 to 31 December 2030 as required 
by Article 8 of EED Recast.  

Ireland has partially addressed recommendation 11. Ireland sets out complete policies and 
measures to achieve the national contributions on energy efficiency, but it does not quantify 
the expected energy savings and the contribution for each of the reported energy efficiency 
measures. Ireland explained how the energy efficiency first principle will be implemented and 
specified robust energy efficiency financing programmes and support schemes. Ireland reports 
existing  policy  measures  to  promote  the  uptake  of  energy  efficiency  lending  products  and 

58 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  
59 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 

50 

 
 
 
 
 
 
innovative  financing  schemes  (such  Energy  Performance  Contractors  and  ESCOs).  Ireland 
established  a  National  Energy  Efficiency  Fund  and  partially  details  its  role  and  provided 
sufficient information on it, by including the use of financial instruments within the Fund.   

Ireland has partially addressed recommendation 12. Ireland does not include an updated 
ambition level to ensure a highly energy efficient and decarbonised national building stock and 
to  transform  existing  buildings into zero-emission buildings by 2050. Also,  an intermediate 
milestone  for  2040  is  missing.  The  milestones  for  the  renovation  of  buildings  include  non-
residential  buildings, in addition  to  residential  buildings. Ireland does not  include sufficient 
information on measures related to buildings in terms of energy savings but included sufficient 
information in terms of funding and costs. The plan includes specific information on policies 
and measures addressing deep renovation, with a specific focus on worst-performing buildings 
and vulnerable consumers, as well as decarbonisation of heating and installation of renewables 
in buildings.   

2.4  ENERGY SECURITY DIMENSION 

Ireland has partially addressed recommendation 13.  The final plan does not further explain 
envisaged measures to diversify gas supply and to continue encouraging gas demand reduction 
towards 2030. The plan only refers to the general objectives of reducing ‘natural gas demand 
and develop renewable, indigenous gas supply and renewable gas-compatible storage’, and to 
the creation of a Strategic Gas Emergency Reserve as well as to the signature of a Memorandum 
of Understanding with the British Government to strengthen existing arrangements in the event 
of a gas supply shock. The plan contains a forecast for gas production, which should move 
from  a  maximum  daily  supply  of  38.7  GWh/d  today  to  14.2  GWh/d  in  2030/31,  which  is 
slightly lower than in the draft plan. Contrary to the draft, the final plan also contains a forecast 
for the evolution of natural gas consumption, which should decrease from 4 294 ktoe in 2021 
to 2 447 ktoe in 2030 and 1 014 ktoe in 2050 (WAM scenario).  

The final plan adds more details on measures related to electricity security of supply, referring 
to  the  Energy  Security  Package  with  several  relevant  actions.  On  storage,  the  plan  sets  an 
objective of additional 1.7 GW of long-duration energy storage by 2030.  This is to allow for 
additional  RES  connection  to  the  grid  and  the  management  of  energy  constraints.  This 
contribution is stated to be needed to reach the objectives of 80% of electricity generation by 
RES and reduction of GHG emissions by 51% in 2030. 

The  plan  contains  forecasts  on  oil  consumption  until  2050.  The  plan  also  describes  the 
measures  being  investigated  to  ensure  the  adequacy  of  oil  infrastructure  in  the  long  run 
(refineries,  oil  stocks)  with  the  expected  oil  demand  decline  and  the  move  to  lower-carbon 
alternatives.    

While the final plan explicitly recognises the importance of climate change for energy security, 
it does not  clearly put  forward policies and  measures  to  integrate  the  imperative of  climate 
adaptation in the energy system. 

51 

 
 
 
 
 
2.5  INTERNAL ENERGY MARKET DIMENSION 

Ireland has partially addressed recommendation 14. The plan has provided an overview of 
an ongoing Demand Strategy with a focus on large energy users but has not provided clear 
targets to improve the flexibility from all potential sources of the energy system.   

The plan does not  elaborate on the quantification of flexibility needs and does not set clear 
targets and objectives for demand response, storage, and flexibility.  The plan does not include 
sufficient  details  on policies and measures that enable a non-discriminatory participation  of 
new  flexibility  services.  In  relation  to  non-discriminatory  participation  in  all  markets  in  all 
timeframes, the plan states that demand side units receive different treatment in the capacity 
market  as  they  do  not  receive  offsetting  energy  payments.  The  plan  states  that  an  enduring 
solution  to  this  issue  is  being  implemented.  However,  there  are  no  details  of  this  enduring 
the 
solution 
solution.  Furthermore,  the  NECP  does  not  provide  information  on  how  Ireland  intends  to 
facilitate system integration of renewable energy in accordance with the revised RED II. 

for  energy  payments  nor 

implementation  of 

timelines 

the 

for 

The plan also outlines a measure to empower consumers in the retail market, such as the Small-
Scale Renewable Electricity Support scheme (SRESS) or the VAT reduction on domestic solar 
panels, although few concrete measures are outlined.  

Ireland partially addressed recommendation 15.  The plan does not provide a concrete target 
for reduction of energy poverty as energy poverty is defined under the social policy. Ireland 
intends to combat energy poverty through measures for increased energy efficiency but does 
not specifically indicate a measurable reduction target for people in energy poverty as required 
by Governance Regulation or under the Energy Efficiency Obligations Scheme (EEOS). The 
NECP refers to the ongoing work to split between the EEOS and alternative measures hinting 
towards additional measures being designed but does not elaborate further. 

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Ireland has partially addressed recommendation 16. The plan includes national objectives 
in  research,  innovation,  and  competitiveness  to  deploy  clean  technologies,  establishing  a 
pathway  for  2030  to  support  the  decarbonisation  of  industry  and  promote  the  transition  of 
businesses towards a net zero and circular economy. Public investment in R&D was at 1.3% 
of  Gross  National  Product  in  2022  (all  sectors)  and  Ireland  has  a  target  of  2.5%  of  Gross 
National Income by 2030.  

The  plan  also  puts  forward  policies  and  measures  to  promote  the  development  of  net-zero 
projects, including those relevant for energy intensive industries, for example in the offshore 
wind  sector.  The  plan  refers  to  the  simplification  of  the  permitting  procedures  as  a  general 
challenge  (Competitiveness  Challenge  2023  Report)  but  does  not  describe  measures  for  a 
predictable  and  simplified  regulatory  framework  for  manufacturing  of  clean  energy 
technologies, nor how access to national funding will be simplified where needed. The plan 
does not provide detailed policies and measures for the digitalisation of the energy system. On 
the development  of  clean energy-related skills, the plan mentions some measures related to 
apprenticeships and Further Education and Training. 

52 

 
 
 
 
 
 
The plan refers to strategies such as, for example, the Powering Prosperity for offshore wind, 
to anchor resilient and sustainable supply chains of key net-zero components and equipment. 
Though  circular  economy  is  a  key  component  of  the  plan,  which  includes  several  related 
policies, details are missing in terms of research, innovation, and competitiveness in the field. 

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Ireland partially addressed recommendation 17. The plan includes estimates of investment 
needs for key low-carbon technologies across various sectors. The estimated total investment 
is approximately €119-125 billion. However, the plan is not clear on the methodology used.  
The plan includes partial information on the public budget planned. Ireland acknowledges the 
critical  role  of  private  sector  financing  for  the  low-carbon  transition,  but  the  strategies  to 
mobilise private investments are not comprehensively explained. The information provided in 
plan is not sufficient to assess a potential financing gap with respect to the investment needs, 
or how this would be filled.  

Ireland  has  not  addressed  the  recommendation  to  provide  a  robust  assessment  of  the 
macroeconomic impact of the planned policies and measures.  The plan indicates that work 
is  ongoing  to  develop  a  modelling  framework  to  analyse  the  macroeconomic,  fiscal,  and 
distributional impacts of the climate transition  

2.8  JUST TRANSITION 

Ireland has partially addressed recommendation 21. The plan provides some information 
on  the  impact  of  the  transition  to  climate  neutrality  on  employment  and skills  but  does  not 
sufficiently assess the impact on the most vulnerable households as Ireland is still developing 
a  macroeconomic  assessment.  The  plan  mentions  the  establishment  of  a  Just  Transition 
Commission  to  advise  and  support  the  Government  in  long-term  just  transition  planning, 
identifying challenges  and opportunities for  the transition  to  climate neutrality. However, it 
does not provide information on its mandate or composition. The plan provides some details 
on the form of support but focusing mainly on JTF and the carbon tax.  

The plan lacks the analytical basis needed for the preparation of the Social Climate Plan, such 
as information on the estimated impact of ETS2, the links to the current carbon tax, and on the 
identification of vulnerable groups. Though the plan indicates that a large share of Ireland’s 
carbon tax revenues is ringfenced to fund measures that contribute to a just transition, it does 
not explain how this will be combined with the resources from the Social Climate Fund. The 
plan does not explain how the policy framework identified in the NECP will contribute to the 
preparation of Ireland’s Social Climate Plan nor how the consistency of the two plans will be 
ensured.  

2.9  PUBLIC CONSULTATION 

Ireland  has  partially  addressed  recommendation  22.  Ireland  organised  two  public 
consultations  following  the  submission  of  the  draft  updated  NECP.  The  plan  details  the 
consultation process for various specific measures. A webinar was organised in June to explain 
the process and the NECP, though this was only seven days before the consultation closed. A 

53 

 
 
 
 
 
Strategic Environmental Assessment (SEA) was still ongoing at the time of the submission of 
the final plan. The plan explains that relevant information (consultation questionnaire, findings 
from the first consultation, reports on the SEA and Appropriate Assessment screening) were 
published together with a questionnaire. The range and type of stakeholders included in the 
process is not clear. 

The plan provides thorough and detailed summaries of the outcome of the consultations, and 
describes their impact on the final plan or explains why some suggestions were not included.  

2.10 REGIONAL COOPERATION 

Ireland  has  partially  addressed  recommendation  23.  The  plan  describes  regional 
cooperation within established frameworks and in other areas, including the development of 
renewables  and  Projects  of  Common  Interest  (PCIs).  The  plan  includes  a  list  of  initiatives 
aiming  at  increasing  Ireland’s  engagement  with  neighbouring  Member  States  for  the 
deployment of renewables and PCIs and other projects, and within the context of the North 
Seas Energy Cooperation (NSEC), for which detailed information on regional cooperation is 
provided. The plan does not mention any progress nor efforts to sign the solidarity agreements 
for  the  security  of  gas  supply  with  Belgium  and  the  Netherlands.   Ireland  does  not  provide 
additional information in its final plan on establishing the framework for cooperation on joint 
projects by 2025 in line with Article 9 of the revised RED II. 

2.11 ANALYTICAL BASIS 

Ireland  has  partially  addressed  recommendation  20.  The  final  plan  provides  an  impact 
assessment of policies and measures with projections reaching 2050. The methodologies used 
are not described in detail. In particular, the updated NECP still does not reference, or describe 
in detail, the analytical framework used for the plan, including energy model.   

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

Ireland has partially addressed recommendation 18. The final plan covers partly the main 
reforms  and  investments  of  the  Recovery  and  Resilience  Plan  (RRP)  that  contribute  to 
implementing the objectives, targets and contributions of the Energy Union. The final plan still 
does not refer to Investment 1.2 (Accelerate the Decarbonisation of the Enterprise Sector) and 
Investment  5.1  (Upscaling  a  Biomethane  Industry  in  Ireland).  Some  of  the  measures  are 
included in the plan without a reference to the RRP as a source of funding, such as Investment 
1.3 (Public Sector Retrofit Pathfinder Project),  Investment  1.4 (Enable future electrification 
through  targeted  investment  in  Cork  commuter  rail)  and  Investment  1.6  (Enhanced 
rehabilitation of peatlands), which are relevant climate and energy reforms and investments of 
the  RRP  and  its  REPowerEU  chapter.  The  majority  of  the  measures  included  in  the  final 
updated NECP are more ambitious than those in the RRP, for example key actions for the built 
environment sector includes a design policy to upgrade 500 000 homes to a B2 Building Energy 
Rating (BER)1 and efforts to install 600 000 renewable energy heating sources.  

54 

 
 
 
 
 
3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

The Commission encourages Ireland to ensure a timely and complete implementation of the 
final  updated  NECP.  Ireland  is  invited  to  pay  particular  attention  to  the  following  main 
elements:  

•  On ESR, implement additional policies towards meeting the 2030 target, closely monitor 
the impacts of the policies included in the plan on emission reductions, increase efforts 
across  all  effort  sharing  sectors.  Explore  possible  available  flexibilities  to  ensure 
compliance with the ESR obligations.  

•  On  LULUCF  and  the  agricultural  sector, consider  promoting  business  models  that 
reduce  carbon  intensity  in  farming,  enhancing  carbon  sequestration  and  diversifying  to 
sectors such as the bioeconomy to create new opportunities for farmers. 

•  Monitor F-gas emissions taking into account the stricter obligations introduced in the 2024 
F-gas  Regulation  (including  through  the  use  of  recapture  methods),  with  particular 
attention to the semi-conductor sector.  

•  On  transport,  expand  public  transportation  networks  and  implement  measures  like 
congestion  pricing  to  encourage  the  use  of  public  transport  and  limit  car  dependency. 
Implement  the  ambitious  targets  for  electric  vehicles  by  prioritising  the  expansion  of 
charging infrastructure, particularly the less served areas. 

•  On adaptation, consider using ongoing policy processes, such as the preparation of the 
climate  change  risk  assessment,  to  assess  quantitatively  relevant  climate  vulnerabilities 
and  risks  for  the  national  objectives,  targets,  and  contributions  and  the  policies  and 
measures  in  the  Energy  Union  dimensions.  That  would  enable  better  outlining  and 
quantifying the link to the specific Energy Union objectives and policies that adaptation 
policies and measures are meant to support, as well as setting out additional adaptation 
policies in sufficient detail.   

•  Detail a timeline for phasing out fossil fuel subsidies, including for high-emission sectors. 
Consider phasing out subsidies for high-emission sectors and providing instead targeted 
support for affected workers and communities to ensure a just transition.  

•  On renewable energy,  develop  a more comprehensive plan on the  acceleration of grid 
expansion and ensure that energy storage and demand response measures are integrated 
into the plan, enhancing the ability of the grid to accommodate renewable energy. Prioritise 
cleaner heating solutions, such as heat pumps and solar thermal energy.  

•  On energy efficiency, detail further the investment plan, including a breakdown by 
dimension  and  a  clearer  public/private  investment  split,  to  help  better  aligning  the 
required  resources  with  the  targets.  Detail  the  strategy  to  implement  and  monitor  the 
energy efficiency first principle. 

•  On buildings, provide more ambitious renovation rates as milestones for the years 2030, 
2040, 2050 and to  clarify the future steps to  ensure the  achievement of  a decarbonised 
building stock.  

55 

 
 
 
 
 
 
Greece  

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Greece’s final updated NECP. 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

2022: -26.6% 
2023: -28%60 

-22.7% 

NECP: 
-43.2%61 

2022: Reported 
net removals of 
-5.4 Mt CO2 eq.  

-1.15 Mt CO2 
eq. (additional 
removal 
target) 

20.4% 
(SHARES) 
17% 
(target) 

2023: 25.3% 

43%  

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for 
additional net GHG 
removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 

Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

National contribution for 
energy efficiency: 

Primary energy 
consumption  

24.7 Mtoe 

2023: 19.88 
Mtoe 

17.8 Mtoe 

Expected to meet 
its target: a 
surplus of – 1.23 
Mt CO2 eq 
compared to the 
2030 target 

EL contribution of 
43% is above the 
39.2% required 
according to the 
formula set out in 
Annex II of the 
Governance 
Regulation62.  

EL primary 
energy 
consumption 
contribution of 
17.8 Mtoe is not 
in line with the 
EED recast Annex 
I formula results: 
17.13 Mtoe 
(Reference 

60  The ESR emissions in 2022 are based on 2024 final GHG inventory reports, and 2023 emissions are based on 
2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as set out 
in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions for 2021-
2025 will only be established in 2027 after a comprehensive review. 
61 As Greece’s NECP does not provide ESR projections, this assessment is based on data provided by Greece in 
February  2025, 
(page  151): 
https://unfccc.int/documents/645147 
62 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’). 

the  UNFCCC  Biennial  Transparency 

as  outlined 

report 

in 

56 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
Scenario) or 17.55 
Mtoe (Updated 
Reference 
Scenario). 

EL final energy 
consumption 
contribution of 
15.2 Mtoe is not 
in line with the 
national 
contribution of 
14.64 Mtoe 
submitted by the 
Commission. 

Greece is below 
the EU-wide 
interconnectivity 
target. 

Final energy consumption 

18.4 Mtoe 

2023: 15.73 
Mtoe 

15.2 Mtoe 

Level of electricity 
interconnectivity (%) 

9.9% 

2024: 4.8% 

15%63 

Source: Eurostat; Greece’s final updated national energy and climate plan 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In December 2023, the Commission published a thorough assessment of Greece’s draft updated 
NECP and provided recommendations64 for the preparation of the final updated NECP. Greece 
submitted its final updated NECP on 26 December 2024, six months after the deadline of 30 
June 2024.65 

2.1  DECARBONISATION 

The final  updated plan commits  to  achieving climate neutrality by 2050. Greece expects  to 
decrease total GHG emissions (including LULUCF and excluding international aviation) by 
57% in 2030, 79% in 2040, and 97% in 2050. 

2.1.1  Effort Sharing Regulation 
Greece has partially addressed recommendation 1. The final NECP does not explain in full 
details how Greece will meet its ESR target of -22.7% by 2030 compared to 2005. The plan 
does not include emissions projections for 2030 for ESR sectors. However, data provided to 
the  Commission  by  Greece  in  February  2025  indicates  that  Greece  is  likely  to  achieve  a 
reduction of 43.2% by 2030, an overachievement of the target of around 20 percentage points.66 
The  final  plan  complemented  the  information  on  the  policies  and  measures  provided  in  the 

63 
Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2024-2025). The 
2030 level represents the general interconnectivity target of 15%. The 2020 figure covers also interconnectors 
with the neighbouring countries outside the EU. 
64 SWD(2023) 929 final, and Commission Recommendation of 18 December 2023, C/2023/9619. 
65 Article 14(2) of Governance Regulation. 
66 The figure is the same included in the 2024 Biennial Transparency Report Greece submitted to UNFCCC.  

57 

 
 
 
 
 
 
 
 
 
draft plan but more details on scope, timeline and expected impact on GHG emissions would 
be useful. The plan covers all ESR sectors comprehensively but lacks data broken down by 
sector.  

The transport sector is the largest source of GHG emissions among ESR sectors in Greece 
and the only one where GHG emissions have increased compared to 1990. The final NECP 
sets more ambitious targets for reducing CO2 emissions from different categories of vehicles 
(e.g. 30% of new vehicles will be electric by 2030), expected to bring a 10% decrease of road 
transport  emissions  between  2022  and  2030.  However,  an  increase  in  emissions  from  the 
maritime sector is expected.  

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings,  road  transport  and  additional  sectors  (ETS2).  The  WAM  scenario  projections 
account for the effect of ETS2, but do not quantify the impact of ETS2 in achieving the ESR 
target.  

On agriculture, the plan provides sufficient detail on how the measures included contribute to 
the ESR target, both in terms of funding and impacts.   

2.1.2  LULUCF 
Greece  has  partially  addressed  recommendation  3.  Greece’s  removals  are  expected  to 
increase in the coming years. The final plan includes projections suggesting that Greece will 
meet its target of -1.15 Mt CO2 eq. (additional removal target) and will generate a surplus of -
1.23 Mt CO2 eq by 2030. 

The  plan  provides  limited  detail  on  how  additional  measures  for  the  land-sector  will  be 
financed. It refers to funding through the CAP 2023-2027 but provides no information on which 
measures the CAP will fund.  Greece indicates that tax policy will play a prominent role but 
does not explain how. The plan clearly explains progress with regards to monitoring, reporting 
and verification (MRV), including for LULUCF emissions and removals. 

2.1.3  Carbon Capture and Storage 
Greece  has  partially  addressed  recommendation  2.  The  plan  includes  estimates  for  how 
much  CO2  can  be  captured  by  2030  (3.1  MtCO2  for  permanent  storage  and  0.2  MtCO2  for 
utilisation). Even though several sources are mentioned (including direct air capture), no split 
by  source  is  defined.  The  plan  outlines  some  plans  for  transport  infrastructure  (mainly  for 
transport  for  liquefication)  and  (as  in  the  draft)  projects  for  storage  capacity,  including  an 
estimate of Total investments. 

2.1.4  Adaptation 
Greece has partially addressed recommendation 4.  The plan refers to the National Strategy 
for Adaptation to Climate Change and to 13 Regional Adaptation Action Plans (RAAPs) to 
respond  to  the  recommendation,  acknowledging  the  importance  of  integrating  adaptation 
planning. An evaluation and revision of the National Strategy is expected to be completed in 
2026.  The  plan  embeds  adaptation  policies  and  measures  in  the  relevant  Energy  Union 
dimensions but lacks detail on their scope and timeline, that would allow an estimation of their 
impact.  

The plan contains a partial analysis of climate vulnerabilities and risks to the achievement of 
national objectives, targets and contributions. The final plan is more thorough compared to the 

58 

 
 
 
 
 
draft  and  contains  an  assessment  of  climate  vulnerability  of  policies  for  greenhouse  gas 
mitigation, renewable energy, energy efficiency, energy security, and critical raw materials. It 
also addresses climate resilience of critical infrastructure. The plan partially outlines the links 
to the specific Energy Union objectives and policies that adaptation policies and measures 
are meant to support. However, their impacts and benefits on other Energy Union objectives 
have generally not been quantified. 

The plan partially addresses the consequences of climate change on future water availability 
and  the  implications  on  the  energy  sector.  National  and  Regional  Adaptation  plans  foresee 
integrating climate change aspects into water planning and water management. The plan refers 
to the impact of the projected climate change induced modification of the annual rainfall pattern 
and  water  availability  on  the  operation  of  thermal  water  plants,  hydrogen  and  biomethane 
production and pumped energy storage or hydropower generation. 

2.1.5  Fossil Fuels 
Greece has partially addressed recommendation 18. The plan includes the commitment to 
phase-out  fossil  fuel  for  power  generation  by  2028,  as  provided  in  national  law,  and 
correspondingly increasing the share of renewable energy sources.   

The plan acknowledges the need to phase out fossil fuel subsidies, listing the main categories 
of subsidies. However, the plan does not set a clear deadline nor a roadmap.  

2.2  RENEWABLES  

Greece has addressed recommendation 5. Greece has put forward an updated contribution 
of 43% as a share for renewable energy in gross final energy consumption which is lower than 
the level of 44% of the draft updated NECP. The contribution of 43% is still slightly higher 
than the level resulting from formula of Annex II of the Governance Regulation. The final plan 
includes an indicative trajectory with the reference points for 2025 (30.9%) and 2027 (36.3%) 
which are above the trajectory calculated in line with the increased EU renewable energy target 
of 42.5% (27% and 32% respectively). 

Greece  has  partially  addressed  recommendation  6.  The  NECP  includes  estimated 
projections for renewable energy technologies over the next 10 years with an outlook to 2040. 
The  plan  provides  indicative  targets  for  buildings  and  industry.  However,  the  final  updated 
NECP does not include a target for innovative renewable energy technologies for 2030 nor the 
minimum level for renewable fuels of non-biological origin (RFNBOs) in industry by 2030. 
Greece states that it does not plan the uptake of RFNBOs in energy and non-energy uses in the 
industry sector before 2030. The plan refers to a share of renewables of 52.6% in heating and 
cooling for 2030, which is in line with the indicative top-ups of Annex 1A of Directive (EU) 
2018/2001  (the  ‘revised  RED  II’)67.  On  transport,  Greece  aims  for  a  RES  target  share  in 
transport  of  13,4%  in  2030  thus  significantly  lower  than  the  legally  binding  target  of  29%. 
Furthermore, the expected share of RFNBO in transport of 0,9% is lower than the 1% set in 

67 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  

59 

 
 
 
 
 
 
the revised RED II for 2030 although the combined share of 5,5% for RFNBO and advanced 
biofuels is reached.  

Greece  has  addressed  recommendation  7.  The  NECP  includes  additional  information  on 
measures  aimed  at  promoting  deployment  of  renewables  in  different  sectors  including  the 
estimated amount of investment but without indicating a specific timeline. 

Additional  measures  that  have  been  adopted  to  facilitate  and  accelerate  permitting  are 
mentioned. Greece mentions its intention to designate renewable acceleration areas following 
the  relevant  energy,  environmental  and  strategic  assessment.  Moreover,  Greece  refers  to  a 
strategy  to  standardise  and  strengthen  power  purchase  agreements  and  elaborates  on  new 
measures to support self-consumption and energy communities, including support schemes for 
solar  PVs  and  storage  installations,  and  creation  of  a  technical  assistance  and  advisory 
mechanism to support renewable energy communities. Even though no specific quantitative 
goals are included, it is mentioned that Law 5037/2023 reserves 10MW of capacity in each 
substation of the Greek distribution system operator for the connection of self-consumers to 
the grid. 

In addition, the plan provides further information on measures aimed at promoting renewables 
deployment in heating and cooling, including installation of hybrid systems and heat pumps 
with significant increase projected during the next decade 2030-2040 due to electrification of 
buildings.  As  regards  renewable  hydrogen  in  industry,  Greece  projects  a  relatively  minor 
demand until 2050 mainly due to focus on electrification. 

Greece partially addressed recommendation 8. The plan does not include a full assessment 
of the domestic supply of forest biomass for energy purposes in 2021-2030 in accordance with 
the strengthened sustainability criteria of the revised RED II nor does it include an assessment 
of the compatibility of the projected use of forest biomass for energy production with Greece’s 
obligations under the revised LULUCF Regulation, particularly for 2026-2030, together with 
national measures and policies to ensure such compatibility. However, Greece has included 
measures to promote sustainable biomethane/biogas production.  

Greece has not addressed recommendation 9, as the plan does not include a specific timeline 
or  procedural  steps  leading  to  the  adoption  of  legislative  and  non-legislative  measures  for 
transposing and implementing of provisions of the revised RED II. 

2.3  ENERGY EFFICIENCY DIMENSION 

Greece has partially addressed recommendation 10. Greece included an indicative national 
contribution of 15.2 Mtoe to the Union’s binding final energy consumption target for 2030. 
This contribution is not in line with Article 4 of Directive (EU) 2023/1791 (‘EED recast’)68 nor 
equal to the corrected indicative national contribution that the Commission submitted to Greece 
in March 2024.  There is still a gap of 3.8% compared to the target calculated with respec to 
the indicative results of the 2020 reference scenario and a gap of 3.5% compared to the target 
calculated with respect to the indicative results of the updated 2020 reference scenario. Greece 

68 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 

60 

 
 
 
 
 
 
included an indicative national contribution of 17.8 Mtoe to the Union’s indicative primary 
energy consumption target for 2030 in line with Article 4.  

Greece did not include the amount of energy consumption reduction per year to be achieved 
by all public bodies nor report the total floor area of heated and cooled buildings owned by 
public bodies to be renovated yearly or the corresponding yearly energy savings to be achieved. 
It also did not specify if opted for the alternative or default approach1. Greece set out policies 
and  measures  to  achieve  the  reduction  of  energy  consumption  from  public  bodies  and  the 
renovation  of  public  buildings,  including  through  the  implementation  of  measures  such  as 
energy performance contracting and the promotion of nearly-zero energy and zero emission 
buildings. 

Greece included the amount of cumulative energy savings of 11.3 Mtoe to be achieved over 
the period from 1 January 2021 to 31 December 2030 in line with Article 8 of EED Recast and 
included  an  explanation  on  how  the  annual  savings  rate  and  the  calculation  baseline  were 
established.  Greece set out complete policies and measures to achieve the required amount of 
cumulative  end-use  energy  savings  by  2030  and  it  quantified  the  energy  savings  from  the 
reported  energy  efficiency  measures  to  ensure  the  achievement  of  the  cumulative  target. 
However, Greece did not include a quantification of the savings from those energy efficiency 
measures targeting energy poverty. 

Greece has partially addressed recommendation 11. Greece sets out comprehensive policies 
and measures to achieve the national contributions on energy efficiency, but it did not quantify 
the expected energy savings and the contribution for each of the reported energy efficiency 
measures, except for those contributing to the achievement of the cumulative energy savings 
target  under  Article  8  of  EED  Recast.  Greece  specifies  robust  energy  efficiency  financing 
programmes and support schemes, including financial instruments and public guarantees, able 
to mobilise private investments and additional co-financing. Greece specified existing policy 
measures to promote the uptake of energy efficiency lending products and innovative financing 
schemes (such as On-Bill and On-Tax schemes, as well as Energy Performance Contractors 
and ESCOs. Greece did not establish a National Energy Efficiency Fund. 

Greece  partially  addressed  recommendation  12.  Greece  does  not  include  an  updated 
ambition level to ensure a highly energy efficient and decarbonised national building stock and 
to transform existing buildings into zero-emission buildings by 2050. Greece only increases its 
ambition  as  regards  residential  buildings  compared  to  the  existing  long-term  renovation 
strategy but not for non-residential, for which Greece does not report any clear intermediate 
milestones  for  2030  or  2040.  Greece  includes  future  milestones  related  to  the  residential 
buildings renovation rates but did not translate them into energy savings milestones. Greece 
details the impact in terms of energy savings of each new measures put forward and included 
sufficient information in terms of funding and costs. Specifically, Greece includes information 
on  policies  and  measures  addressing  deep  renovation,  with  a  specific  focus  on  worst-
performing  buildings  and  vulnerable  consumers,  as  well  as  decarbonisation  of  heating  or 
installation of renewables in buildings.  

61 

 
 
 
 
 
2.4  ENERGY SECURITY DIMENSION 

Greece has partially addressed recommendation 13.  On gas, consumption is expected to 
substantially  decrease,  while  on  electricity  the  final  plan  emphasises  the  objective  of 
completing  the  interconnection  of  the  islands,  where  it  adds  more  details  on  the  individual 
projects in terms of capacity and costs. Additional details on storage systems are also included.  

In the oil sector, the plan includes long term projection of liquid fuel consumption post 2030, 
however the plan does not assess the adequacy of the oil infrastructure (refineries, oil stocks) 
in the long run with the expected oil demand decline and the move to lower-carbon alternatives. 

The  final  plan  contains  significantly  more  information,  with  a  detailed  assessment  of  the 
climate vulnerabilities of all energy sources as well as of energy efficiency and energy security 
policies.  This  includes  measures  to  protect  transmission  systems  from  climate  change, 
including physical protection against fire or floods. 

2.5  INTERNAL ENERGY MARKET DIMENSION 

Greece has partially addressed  recommendation 14.  Greece does not  quantify flexibility 
needs but includes policies and measures to enhance flexibility. The plan presents five policy 
priorities  for  the  internal  energy  market,  one  of  which  is  to  promote  systems  that  provide 
flexibility,  including  storage  and  demand  response.  Greece  reports  that  the  ongoing 
amendments to the regulatory framework will allow for a full participation of demand response 
and storage to the electricity markets. As such, Greece expects the demand response capacity 
to increase and the total capacity of batteries storage to reach 4.3 GW, and the total capacity of 
pumped hydro storage to reach 1.9 GW by 2030.  

Even though the plan provides a good overview of measures promoting flexibility to facilitate 
energy  system  integration,  it  does  not  provide  information  on  specific  measures  related  to 
facilitating system integration of renewable electricity in accordance with Article 20a of the 
revised RED II. 

Among  other  measures,  the  plan  also  commits  to  expand  demand  response  measures  to 
encompass all consumers. Accordingly, Greece aims to significantly increase the penetration 
of smart meters, with the goal to completely replace conventional meters with smart meters by 
2030. 

The  plan  includes  measures  and  programmes  to  empower  consumers  and  particularly  to 
promote self-consumption, for instance through existing programmes ‘Photovoltaic at Home’ 
and ‘Photovoltaic in the field’, 15.000 self-consumption plants are now in operation since 2024, 
with a total installed capacity close to 500 MW, and connection servers have been provided for 
17,000 plants with a capacity of 700 MW. Measures are also put in place to further allow for 
self-consumption through renewable and citizen energy communities.  

Greece has addressed recommendation 15. This plan significantly improves the analysis and 
detailing of measures to tackle energy poverty, including the articulation of specific initiatives 
and the associated financial frameworks necessary for their implementation. The updated plan 
offers  a  comprehensive  approach  to  energy  poverty,  outlining  concrete  measures  such  as 
energy  upgrades  in  residential  buildings  and  support  for  renewable  energy  installations  in 

62 

 
 
 
 
 
 
affected households. Furthermore, the plan specifies the deployment of these measures through 
the Energy Efficiency Obligation Scheme, which forms part of a broader strategy aimed not 
only  at  alleviating  immediate  energy  costs  but  also  ensuring  long-term  sustainability  for 
affected populations. Additionally, the plan improves the linkage between planned actions and 
the financial resources dedicated to  them. While  the  final  plan  advances the specificity and 
scope of strategies to mitigate energy poverty as was recommended, it could further enhance 
transparency by detailing the exact financial allocations for each measure and clearly outlining 
their expected impacts on reducing energy poverty among vulnerable groups. 

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Greece  partially  addressed  recommendation  16.  The  plan  includes  a  comprehensive 
approach,  although  it  does  not  include  specific  targets  to  support  research,  innovation,  and 
competitiveness  in  clean  energy  technologies,  establishing  a  pathway  to  2030  and  2050. 
Significant  policies  and  measures  include  scaling  up  manufacturing  capacities  in  the  value 
chain  of  zero-emission  technologies  and  supporting  innovative  production  processes  like 
photovoltaics,  offshore  wind  infrastructure,  and  hydrogen.  Targets  for  development  of 
technologies focusing on hard-to-decarbonize sectors and heavy transport applications, as well 
as  enhancement  of  competitiveness  through  innovation  in  technologies  supporting  a  zero-
emission  circular  economy  are  also  mentioned  for  2050.  The  plan  includes  measures to 
promote  the  development  of  net-zero  projects  including  those  relevant  for  energy  intensive 
industries. The NECP mentions all the amendments that already began to simplify permitting 
and, more specifically, that to support entrepreneurship, the existing licensing framework for 
zero-emission  technologies  in  energy-intensive  industries  will  be  improved.  and  access  to 
national funding will be simplified where needed. The plan includes information on policies 
and measures for the development of clean energy related skills and to facilitate resilient and 
sustainable supply chains of key net-zero components and equipment.  

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Greece partially addressed recommendation 17. The plan provides aggregate estimates of 
investment  needs  per  sector  but  does  not  specify  the  share  of  public  and  private  sources. 
Investment  needs  and  funding  sources  are  not  provided  for  each  measure,  though  the  plan 
includes  a  high-level  assessment  of  national  and  EU  funding  sources.  The  plan  does  not 
elaborate on measures and initiatives required to mobilise private investments. The information 
provided in the plan is not sufficient to estimate a potential financing gap and assess how this 
would be filled. 

Greece partially  addressed  the  recommendation to provide a  robust assessment of the 
macroeconomic  impact  of  the  planned  policies  and  measures.  The  plan  contains  a 
quantitative and qualitative assessment of the macroeconomic impact on selected variables but, 
does not include a “no policy change” or counterfactual macro-economic scenario. 

2.8  JUST TRANSITION 

Greece has partially addressed recommendation 20. The plan provides information on the 
impact of the transition to climate neutrality on employment and skills but does not sufficiently 

63 

 
 
 
 
 
address  the  social  impact  on  the  vulnerable  households.  Moreover,  the  plan  outlines  the 
financing sources, including substantial EU funds, without providing information on the impact 
of initiatives or the resources available.  

The plan commits to phasing out fossil fuel power generation, mainly lignite, by 2028 as also 
indicated  in  the  Territorial  Just  Transition  Plans  (TJTPs).  However,  the  plan  does  not 
sufficiently explain the alignment between the NECP and TJTPs regarding the coal phase out 
in the individual lignite-powered plants  

The plan lacks the analytical basis needed for the preparation of the Social Climate Plan, such 
as information on the estimated impact of ETS2 and the identification of vulnerable groups, 
even though many measures aiming at fighting energy poverty are mentioned. The plan does 
not explain how the policy framework identified in the plan will contribute to the preparation 
of Greece’s Social Climate Plan nor how the consistency of the two plans will be ensured.  

2.9  PUBLIC CONSULTATION 

Greece has partially addressed recommendation 21. Greece organised several presentations 
of the draft and final updated NECP within different governance structures and with specific 
national  bodies  and  stakeholders.  In  some  cases,  the  presentations  were  accompanied  by  a 
questionnaire. The consultation on the final plan with civil society took place from 22 August 
to  16  September  2024,  after  the  formal  submission  date  of  30  June.  The  outcomes  were 
presented to the Greek Parliament in October. 

The plan includes a summary of the outcome of the consultations, with figures on the type of 
respondent (e.g. NGO, company), and on the thematic categories of the comments. However, 
the plan does not describe how the input from stakeholders was integrated. 

2.10 REGIONAL COOPERATION 

Greece has partially addressed recommendation 22, stressing the need to further intensify 
regional cooperation with neighbouring Member States within CESEC and to pursue further 
efforts  in  the  security  of  gas  supply  field.  The  plan  elaborates  in  detail  how  Greece  is 
participating in regional structures and the bilateral relations that it pursues. It does not specify 
in much detail future actions to intensify regional cooperation in specific areas, however. The 
plan  also  does  not  contain  information  on  Greece’s  plans  to  establish  a  framework  for 
cooperation with other Member States by 2025, in line with Article 9 of the revised RED II. 

The final plan does not refer to efforts or progress regarding the signature of the two bilateral 
solidarity agreements for the security of gas supply with its neighbours (Bulgaria and Italy). 

2.11 ANALYTICAL BASIS 

Greece has not addressed recommendation 19. The final plan includes projections for the 
cost of electricity by 2050 but still does not provide projections under the planned policies and 
measures  on  how  the  energy  system  will  develop.  Moreover,  the  plan  does  not  include 
projections on GHG emissions for sectors covered by the Effort Sharing Regulation.  

64 

 
 
 
 
 
 
2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

The  final  NECP  for  Greece  covers  sufficiently  the  main  reforms  and  investments  of  the 
Recovery and Resilience Plan (RRP) that contribute to implementing the objectives, targets, 
and contributions of the Energy Union.   

3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

The Commission encourages Greece to ensure timely and complete implementation of the final 
updated NECP. Greece is invited to pay particular attention to following main elements:  

•  Analyse the impact on GHG emissions of policies in the effort sharing sectors to confirm 

progress towards meeting the 2030 ESR target.  

•  On  adaptation,  assess  quantitatively  climate  vulnerabilities  and  risks  regarding  the 
achievement  of  the  national  objectives,  targets,  and  contributions  and  the  policies  and 
measures in the different Energy Union dimensions. That would enable better outlining and 
quantifying the link to the specific Energy Union objectives and policies that adaptation 
policies  and  measures  are  meant  to  support,  as  well  as  setting  out  additional  adaptation 
policies and measures in sufficient detail. 

•  Set a clear roadmap with specific measures to phase out fossil fuel subsidies. 
•  On industry, consider additional actions to reduce the GHG emissions intensity in energy-

intensive sectors. 

•  Move forward on putting in place a framework for facilitating energy system integration 
to efficiently integrate increased shares of variable renewable energy across sectors notably 
in buildings and industry, including via increased deployment of energy storage. 

•  Swiftly implement the planned reforms related to simplification of permit-granting and 
administrative procedures for deployment of renewables in line with the revised RED II, 
including considering the key role of local communities and alternative dispute resolution 
approaches.   

•  On  transport,  consider  further  energy  efficiency  measures,  as  only  5.7%  of  the 
cumulative savings are expected to come from measures targeting transport. Ensure proper 
implementation  of  policies  such  as  incentives  for  public  passenger  transport,  freight 
transport  regulation,  awareness  raising  campaigns  to  support  the  decarbonisation  of  the 
sector.  Given  the  low  adoption  rate  of  electric  passenger  cars  compared  to  other  EU 
countries, support the proposed targets for EV uptake by introducing robust demand-side 
measures. 

•  On energy efficiency, put  in  place measures to  achieve the higher ambition  for  energy 

efficiency by 2030. 

•  On buildings, ramp up the pace and depth of renovations, especially in the non-residential 
building  stock,  and  strengthen  regulatory  enforcement  and  address  market  barriers  to 
achieve the objectives set in the Long Term Renovation Strategy.  

•  Swiftly proceed with implementing the NECP measures to address energy poverty. Further 
clarify  and  detail  financial  allocations  and  funding  streams  to  facilitate  more  effective 

65 

 
 
 
 
 
monitoring and evaluation of impacts, ensuring that resources are efficiently targeted, and 
outcomes align with the broader objectives of energy sustainability and social equity. 
•  Develop a comprehensive just transition strategy which addresses all vulnerable groups 

and allocates sufficient funding resources. 

66 

 
 
 
 
 
 
Spain  

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Spain’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

2022: -19.5% 
2023: -20.9%69 

-37.7% 

NECP:  
-44.6% 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for net 
GHG removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 

Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

National contribution for 
energy efficiency: 

Reported net 
removals of  
-47.4 Mt CO2 
eq. in 2022 

-5.3Mt CO2 
eq. (additional 
removal 
target) 

21.2% 
(SHARES) 
20% 
(target) 

13% 
relative to 
reference 
scenario 

2023: 25% 

48% 

-13.4% by 2020 

43% 
compared to 
BAU without 
measures 

Primary energy 
consumption  

123.4 
Mtoe  

2023: 110.1 
Mtoe 

98.4 Mtoe 

Insufficient 
ambition based on 
projections: A gap 
of 6.11 Mt CO2 
eq. compared to 
the 2030 target 

ES contribution of 
48% is in line 
with the required 
level pursuant the 
formula of Annex 
II of the 
Governance 
Regulation70 

ES primary energy 
consumption 
contribution of 
98.4 Mtoe is not in 
line with the EED 
recast Annex I 
formula results: 
81.8 Mtoe 
(Reference 
Scenario) or 82.2 
Mtoe (Updated 
Reference 
Scenario) 

69 
The ESR emissions in 2022 are based on 2024 final GHG inventory reports, and 2023 emissions are based 
on 2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as set 
out in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions for 
2021-2025 will only be established in 2027 after a comprehensive review. 
70 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’). 

67 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
  
 
Final energy consumption 

86.3 Mtoe 

2023: 80.6 Mtoe 

71.709 Mtoe 

Level of electricity 
interconnectivity (%)71 

6.5% 

2024: 4.2% 

15% 

Source: Eurostat; and Spains’s final updated national energy and climate plan 

ES final energy 
consumption 
contribution of 
71.7 Mtoe is not 
in line with the 
national 
contribution of 
66.3 Mtoe 
submitted by the 
Commission. 

ES is below the 
EU-wide 
interconnectivity 
target. 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In December 2023 the Commission published a thorough assessment of Spain’s draft updated 
NECP and provided recommendations72 for the preparation of the final updated NECP. Spain 
submitted its final updated NECP on 25 September 2024, three months after the deadline of 30 
June 2024.73 

2.1  DECARBONISATION 

Spain  expects  to  decrease  total  GHG  emissions  (including  LULUCF  and  excluding 
international aviation) by 32% in 2030 compared to 1990 levels, and to reach climate neutrality 
by 2050.  

2.1.1  Effort Sharing Regulation 
Spain has addressed recommendation 1. The final NECP provides sufficient details on how 
Spain will meet its ESR target of 37.7% by 2030 compared to 2005.  

The  plan  provides  the  same  projections  as  in  the  draft  plan,  showing  that  the  existing  and 
planned policies and measures will lead to a decrease of 44.6% in 2030 compared to 2005, an 
overachievement of 6.9 percentage points compared to the national ESR target. In 2022, GHG 
emissions from effort sharing sectors represented around 66% of the total in Spain (expected 
to be around 69% in 2030)74, with transport projected to represent the largest share. The ‘with 
additional measures’ (WAM) projected value for ESR in 2030 is roughly 22% lower than the 
projection under the ‘with existing measures’ (WEM) scenario, hinting that implementing the 
plan will require a significant effort. The final plan complements the information on the policies 

72 SWD(2023) 913 final, and Commission Recommendation of 18 December 2023, C/2023/9603. 
73 Article 14(2) of Governance Regulation. 
74 Share  of  total  GHG  emissions  excluding  LULUCF.  Source:  Commission  calculations  based  on  the  Spanish 
final updated NECP and GHG inventories submitted to EEA.  

68 

 
 
 
 
 
 
 
 
 
 
and measures provided in the draft, though not always complete on the scope, timeline and 
expected GHG emissions reduction.  

The  plan  focuses  on  all  the  key  sectors  and  sources  of  GHG  emissions.  In  2022,  transport 
accounted for around 45% of Spain’s ESR emissions.75 The WAM projections for transport 
describe a significant change of trend in emissions in the period 2022-2030, with an average  
decrease per year of 5.7%, compared to the annual increase of 1.05% in the period 2015-2022.76 
This  is  the  result  of  the  modal  shift  to  public  transport,  shared  mobility  and  zero-emission 
vehicles, in synergy with the low-emission zones in cities with more than 50.000 inhabitants. 
The plan foresees the presence in 2030 of more than 5.5 million electric vehicles, and the use 
of sustainable or advanced biofuels. 

On agriculture, the final plan maintains an approach similar to the draft, addressing methane 
and nitrous oxide emissions from manure management, as well as nitrous oxide emissions from 
agricultural soils. However, the plan still lacks specific measures to tackle methane emissions 
from  enteric  fermentation  of  cattle,  which  constitutes  the  predominant  source  of  non-CO2 
emissions and is a significant contributor to Spain’s overall GHG emissions in the ESR sectors. 

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings,  road  transport  and  additional  sectors  (ETS2).  The  scenario  projections  do  not 
account for the effect of ETS2 and do not quantify the impact of ETS2 on the ESR target. 

2.1.2  LULUCF 
Spain has partially addressed recommendation 3. The LULUCF sector in Spain generates 
net removals, absorbing roughly 16% of the total GHG emissions in 2022. According to the 
LULUCF Regulation,  Spain  has to  improve its  net  removals by  -5.3 Mt  CO2eq. in  2030 as 
compared to its yearly average in the 2016-2018 reference period. Considering its projections 
for 2030, Spain will still have a gap of 6.11 Mt CO2eq in 2030. The final plan does not contain 
new measures compared to the ones in the draft, which are acknowledged to be insufficient for 
reaching  the  target.  Climate  change  impacts  are  still  recognised  to  be  a  major  issue  for 
enhancing  removals.  While  the  plan  shows  some  progress  in  facing  these  impacts  (i.e.  the 
approval  of  a  National  Strategy  to  Combat  Desertification  and  the  implementation  of  the 
National Adaptation Plan 2021-2030), it does not indicate impacts on mitigation. In this regard, 
the plan mentions the importance of the flexibility in the Regulation (article 13b (6)) to comply 
with the target. The plan does not provide new information on how public funding (CAP, State 
aid) and private financing through carbon farming schemes are used to  reach the LULUCF 
target. The draft also lacks information on the status and progress of ensuring higher tier levels 
and geographically explicit datasets, needed for the robustness of net removal estimates. 

Overall,  based  on  the  available  information,  Spain  does  not  design  sufficiently  effective 
policies to support the land sector and the achievement of the LULUCF target. 

76 Compound annual growth rate 

69 

 
 
 
 
 
 
 
 
2.1.3  Carbon Capture and Storage 
Spain has not addressed recommendation 2. The plan does not provide a comprehensive 
CCUS strategy. It does not contain an estimate of Spain’s expected storage capacity and does 
not provide annual injection capacity targets, nor examples of ongoing/planned CCUS projects. 
Nonetheless, the plan mentions EUR 2.37 billion financing (EUR 870 million in grants and 
EUR 1.5 billion in loans) for the decarbonisation of manufacturing industry, including CCUS 
projects. 

2.1.4  Adaptation 
Spain has not addressed recommendation 4. The plan refers to the National Climate Change 
Adaptation  Plan  for  2021-2030,  acknowledging  the  importance  of  integrating  adaptation 
planning. While the plan is already rather comprehensive and embeds adaptation policies and 
measures  in  the  relevant  Energy  Union  dimensions,  it  lacks  the  details  on  their  scope  and 
timeline needed for an estimation of their impact.  

The  plan  sets  out  a  significant  array  of  additional  adaptation  policies  and  measures  to 
support  the  achievement  of  national  objectives,  targets  and  contributions  under  the  Energy 
Union, but provides insufficient details to assess their scope, timing and likely impact.  

The  plan  partially  addresses  the  consequences  of  climate  change  on  future  water 
availability  and  its  implications  on  the  energy  sector.  However,  it  lacks  a  fully 
comprehensive forward-looking assessment of future water demand and available supply at the 
national  scale,  aligned  with  expected  climate  warming  trajectories.  While  it  proposes 
desalination and renewable hydrogen as solutions, it does not adequately consider the potential 
cross-sectoral conflicts, such as with energy production, agriculture, and residential water use 
in the face of growing water scarcity.  

2.1.5  Fossil Fuels 
Spain  has  partially  addressed  recommendation  16.  The  plan  includes  a  commitment  to 
phase out fossil fuel subsidies, but does not clearly explain how, in terms of specific measures 
and  timeline.  The  plan  simply  includes  a  reference  to  the  COP28  outcome  on  phasing  out 
inefficient  fossil  fuels,  and  examples  of  subsidies  provided  to  support  the  deployment  of 
renewable energy, as well as a rather generic ban on hydrocarbon exploration and exploitation 
activities. 

2.2  RENEWABLES 

Spain has partially addressed recommendation 5. The final updated NECP does not provide 
estimated  trajectories  nor  a  long-term  plan  for  the  deployment  of  renewable  energy 
technologies.  Although  the  NECP  does  not  include  an  indicative  target  for  innovative 
renewable energy technologies by 2030, it includes a plan to adopt such a target and measures 
expected to achieve it, in line with Directive (EU) 2018/2001 (the ‘revised RED II’)77.   

Spain has partially addressed recommendation 6. The plan provides additional details on 
the policies and measures to enable a timely and cost-effective achievement of Spain’s national 
contribution to the Union’s binding renewable energy target of 42.5% in 2030, in line with the 

77 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  

70 

 
 
 
 
 
 
revised RED II. It also sets targets for advanced biofuels and RFNBOs in the transport sector. 
Although  the  plan  does  not  provide  details  on  the  implementation  of  the  provisions  on 
“renewables acceleration areas” with faster and simpler procedures, the policies and measures 
presented contain additional elements on the zoning aspects of renewable deployment.  

Spain  has  partially  addressed  recommendation  7.  The  plan  does  not  provide  additional 
information  on  the  trajectories  of  bioenergy  supply  by  feedstock  and  origin,  on  bioenergy 
demand and on sustainability, nor an assessment of the domestic supply of forest biomass for 
energy purposes in 2021-2030. It does not include either an assessment of the compatibility of 
the  projected  use  of  forest  biomass  for  energy  production  with  Spain’s  obligations  under 
Regulation  (EU)  2018/841  as  amended,  particularly  for  2026-2030,  together  with  national 
measures  and  policies  to  ensure  such  compatibility.    Finally,  Spain  includes  measures  to 
promote the sustainable production of biomethane/biogas. 

Spain has partially addressed recommendation 8. The plan contains several references to 
an  upcoming  royal  decree  transposing  the  revised  RED  II,  while  not  providing  a  specific 
timeline.  

2.3  ENERGY EFFICIENCY DIMENSION 

Spain  has  partially  addressed  recommendation  9.  Spain  includes  an  indicative  national 
contribution to the Union’s binding final energy consumption target for 2030 of 71.7 Mtoe for 
final  energy  consumption.  This  contribution  is  not  in  line  with  Article  4  of  Directive  (EU) 
2023/1791 (‘EED recast’)78, nor equal to the corrected indicative national contribution that the 
Commission submitted to Spain in March 2024 under Article 4(5) of EED recast. There is still 
a  gap  of  8.2%  compared  to  the  target  calculated  with  respect  to  the  corrected  indicative 
contribution79.  Spain  includes  an  indicative  national  contribution  to  the  Union’s  indicative 
primary energy consumption target for 2030 of 98.4 Mtoe for primary energy consumption. 
This  contribution  is  not  in  line  with  Article  4  of  EED  recast.  There  is  still  a  gap  of  20.3% 
compared  to  the  target  calculated  with  respect  to  the  indicative  results  of  the  2020  refence 
scenario, and a gap of 19.7% compared to the indicative results of the updated 2020 reference 
scenario. Spain does not include the amount of energy consumption reduction per year to be 
achieved by all public bodies as required by Article 5 of EED Recast.  

Spain does not report the total floor area of heated and cooled buildings owned by public bodies 
to  be  renovated  each  year80 nor  the  corresponding  yearly  energy  savings  to  be  achieved  as 
required by Article 6 of EED Recast but opts for the default approach81. Spain sets out policies 
and  measures  to  achieve  the  reduction  of  energy  consumption  from  public  bodies  and  the 
renovation of public buildings. 

78 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 
79 Spain explained in the final NECP that the 2020 EU Reference Scenario does not reflect the conditions of the 
energy system of Spain and they use as baseline the PRIMES 2007 scenario. 
80 It reported as requirement the 300,000 m2 per year in General State Administration plus the expansion of the 
3% to other territories. The new inventory is under elaboration.  
81 Spain included a target for General State Administration to be expanded to the 3% of other territories in terms 
of m2. From this, it could be concluded that the implementation of default approach will be maintained. 

71 

 
 
 
 
 
 
Spain has partially addressed recommendation 10. Spain includes an updated ambition level 
regarding the progress on final energy savings and renewable integration for the building sector 
in 2030. The targets for the building sector do not disaggregate between the public sector and 
private sector. Spain also states the objectives for 2050, with a reference to the national Long 
Term  Renovation  Strategy.  The  plan  refers  to  the  same  strategy  regarding  milestones, 
indicators, and intermediate targets for 2030 and 2040, although these are not included in the 
plan.  The  plan  mentions  some  of  the  measures  that  could  be  used  to  support  the  overall 
objectives, but these are very limited, and they lack details and definition. 

2.4  ENERGY SECURITY DIMENSION 

Spain has partially addressed recommendation 11. The plan does not further explain how 
Spain intends to encourage gas demand reduction or develop detailed policies and measures to 
reach this objective towards 2030. It provides some forecasts for the evolution of natural gas 
net imports, which are expected to decrease from 27 874 ktoe in 2020 to 17 940 ktoe in 2030, 
and domestic production, which is  expected to  increase from  42  ktoe in  2020 to  49 ktoe in 
2030.  

For  electricity,  Spain  mentions  that  a  new  energy  and  climate  security  strategy  will  be 
approved, although no date was specified. The strategy will be built around the acceleration of 
the  energy  transition,  the  protection  of  the  energy  and  industrial  supply  chain,  and  the 
mitigation and adaptation to climate change. The plan also refers to the completion of the final 
version of the risk-preparedness plan in the electricity sector. Energy storage is mentioned as a 
way to manage the growth of non-dispatchable renewable generation and increase flexibility. 
Here the target was raised to 22.5 GW, a slight increase from the draft updated NECP.  

The  plan  does  not  include  forecasts  on  oil  consumption  until  2050  and  does  not  assess  the 
adequacy  of  the  oil  infrastructure  in  the  long  run  (refineries,  pipeline,  oil  stocks)  with  the 
expected oil demand decline and the move to lower-carbon alternatives. 

As regards nuclear, the plan provides information on the diversification of nuclear materials 
and fuel, and on the plans and financing of long-term management of nuclear waste. The plan 
does not provide information on the supply of spare parts but indicated that Spain has a large 
sector of engineering and service companies in the field of nuclear energy, including for the 
manufacturing of nuclear fuel assemblies. 

2.5  INTERNAL ENERGY MARKET DIMENSION 

Spain has partially addressed recommendation 12. The plan does not quantify flexibility 
needs  nor  does  it  set  clear  targets  for  demand  response,  storage,  and  flexibility.  The  plan 
acknowledges the importance of system flexibility to achieve the renewable targets and states 
that  the  national  measures  introduced  are  well  advanced.82 The  plan  also  elaborates  on  the 
measures set out at national level aiming to foster flexibility such as aid programmes for energy 
storage  and  promotion  of  local  flexibility  markets.  Spain  projects  a  slight  increase  in  the 
expected storage capacity installed by 2030, from 22 GW to 22.5 GW. 

82   See p. 173 

72 

 
 
 
 
 
 
 
The plan states that a national assessment of flexibility needs is on-going following the reform 
of the Electricity Market  Design  (EMD).  However, so far, regarding the indicative national 
objectives  for  non-fossil  flexibility  introduced  by  the  EMD  reform,  the  plan  only  defines 
objectives for energy storage.83 The plan does not set out monitoring indicators to quantify the 
progress made towards those targets but only specifies the need for establishing a remuneration 
framework.  

The  plan  refers  to  developing  more  competitive  retail  electricity  markets  and  increasing 
consumer  empowerment.  However,  the  plan  remains  vague  on  the  possible  measures  that 
would achieve these objectives. 

Spain partly addressed recommendation 13. Whilst measure 4.2 of the plan does include a 
description  of  social  policy  and  structural  energy  measures  deployed  under  the  National 
Strategy  against  Energy  Poverty,  including  promotion  of  social  rental  and  renovations  of 
buildings, their scope is not described in detail nor correlated with specific measurable targets 
or details of the financial resources for the implementation of the described policies. General 
measurable targets based on relevant indicators of energy poverty are included but limited until 
2025. No explanation on the use of energy efficiency measures under the Energy Efficiency 
Obligation  Scheme  to  alleviate  energy  poverty  is  provided.  Overall,  the  plan  would  have 
benefitted from a stronger link to the New Energy Poverty Strategy developed in 2024. 

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Spain  has  partially  addressed  recommendation  14.  The  plan  provides  a  comprehensive 
approach,  including  strategies  and  measures  to  support  research,  innovation  (R&I)  and 
investments in clean energy technologies, the circular economy and the digitalisation of the 
energy value chain. Spain includes energy transition and decarbonisation as a strategic priority 
in  the  national  Plan  for  Investigation,  Science,  Technology  and  Innovation  (PEICTI)  and 
concrete measures in the NECP to support R&I in the energy sector84. While the plan does not 
include a specific breakdown of investment in R&I for the energy sector for 2030 and 2050 
and more could be done to quantify current spending and objectives, it provides measures for 
regional  (coordination  between  Autonomous  Communities)  and  international  cooperation 
(Mission Innovation) in  this area. There is also a good alignment with the Strategic Energy 
Technology Plan (SET Plan) and the European R&I funding programmes.  

The  plan  outlines  measures  to  promote  the  development  of  net-zero  projects  and  to  boost 
technology  improvements  for  energy  intensive  industries.  The  plan  describes  actions  to 

83 See p. 141 and ff referring to the 2021 Energy Storage strategy which sets out an objective of 22.5 GW of energy 
storage by 2030, out of which 12.5 GW of daily and weekly storage and 10 GW of seasonal storage. Based on the 
information provided, these targets are not specific to non-fossil energy storage. 
84 Such as innovative renewable energy installations (offshore  wind, energy storage,  biogas, floating PV,  CSP 
with  storage,  deep  geothermal);  demand  response  and  storage  pilots;  innovative  business  models  to  enhance 
flexibility  digitalised  and  competitive  energy  system,  including  storage;  energy  efficiency  in  buildings  and 
industry, smart cities and communities; renewable fuels and energy vectors. 

73 

 
 
 
 
 
 
 
facilitate resilient and sustainable supply chains of key net-zero components and equipment85. 
However, it does not describe how Spain will ensure a predictable and simplified regulatory 
framework for permitting procedures for manufacturing, nor how access to national funding 
will be simplified where needed.  

The plan includes information on policies and measures for the development of clean energy-
related skills.  

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Spain partially addressed recommendation 15. The final updated NECP does not provide 
detailed estimates of the investment needs for each policy initiative. Nevertheless, it includes 
an estimate of the total investment needs and a breakdown by policy priority (e.g. renewables, 
energy efficiency, grids, electrification, etc.) and a split for public and private sources. Funding 
gaps are not identified. The estimates are based on a robust top-down analysis. 

The plan occasionally outlines the sources of funding per measure and project, but this is not 
done in a consistent way. The plan does not provide an overview of the instruments envisaged 
to mobilise private investments.  

Spain  partially  addressed  the  recommendation  to  provide  a  robust  assessment  of  the 
macroeconomic impact of the planned policies and measures. A more detailed explanation 
of the different impacts would further enhance the quality of the assessment. Moreover, the 
estimated impact on GDP seems inconsistent with Spain’s mid-term fiscal sustainability plan. 

2.8  JUST TRANSITION 

Spain  has  partially  addressed  recommendation  17.  The  plan  presents  the  existing  Just 
Transition  Strategy,  aiming  at  maximising  employment  opportunities  and  minimising  the 
impacts  of  the  energy  transition,  the  Framework  Agreement  for  a  Just  Transition  of  Coal 
Mining and the Just Transition Conventions. It also provides an analysis of the impacts of the 
transition  to  climate neutrality  on skills, training, overall  employment conditions  and social 
needs.  Nonetheless,  the  employment  and  social  impacts  for  workers  or  regions  are  not 
specified. Moreover, the plan does not specify the form of support, the impact of initiatives or 
the resources available, except for the JTF and the cohesion policy programmes 

The plan lacks the analytical basis needed for the preparation of the Social Climate Plan, such 
as information on the estimated impact of ETS2 and the identification of vulnerable groups, 
except for the definition of energy poverty, which is already established in Spain. The plan 
partly  explains  how  the  policy  framework  identified  in  the  NECP  will  contribute  to  the 
preparation of Spain’s Social Climate Plan and how the consistency of the two plans will be 
ensured.  

85 (PERTE ERHA includes support for new manufacturing lines or capabilities for components; PERTE Industrial 
Decarbonisation features an aid line for new highly efficient and decarbonised manufacturing facilities is foreseen, 
as  well  as  a  new  investment  included  in  an  addendum  to  the  RRP  to  support  the  launch  or  upgrade  of 
manufacturing  facilities  for  renewable  generation,  storage  and  renewable  hydrogen  generation,  storage, 
distribution, consumption components and systems). 

74 

 
 
 
 
 
 
2.9  PUBLIC CONSULTATION 

Spain  has  addressed  recommendation  18.  Spain  organised  several  rounds  of  public 
consultations starting in August 2022. The consultations were organised in different moments 
during the preparation of the updated NECP, online, through workshops in person and advisory 
bodies, with a broad participation of stakeholders, citizens, and public institutions. The public 
consultation process on the draft plan took place from 28 June to 4 September 2023, and on the 
final  plan  in  March  and  June  2024.  For  the  latter,  there  was  a  significant  increase  in 
participation. A consultation in the context of the Strategic Environmental Assessment of the 
plan  took  place  in  June  and  lasted  a  month.  The  plan  includes  a  summary  of  the  main 
contributions received. However, it is not clear how the views expressed have been considered 
in the final plan.  

2.10 REGIONAL COOPERATION 

Spain has partially addressed recommendation 19. The plan adequately addresses the role 
of  regional  cooperation  in  the  framework  of  the  High-Level  Group  for  Interconnection  in 
South-West Europe (SWE), describing the main objectives of the cooperation in the fields of 
electricity  interconnections,  hydrogen,  and  offshore  infrastructures,  as  well  as  the  latest 
developments (new Memorandum of Understanding) and planned actions (SWE Action Plan). 

The plan does not refer to any progress or efforts to undertake as regard the signature of the 
bilateral solidarity agreements for gas supply with Spain’s neighbours (Portugal and France). 

2.11 ANALYTICAL BASIS 

The plan provides a description of the analytical framework, with projections only until 2030. 
It covers economic, employment, distributional, and health impacts.  

The plan relies on robust quantitative analysis based on well documented models. It provides 
a  rather  short  assessment  of  the  macroeconomic  impacts  of  policies  and  measures, 
complemented by a sensitivity analysis of the impacts of energy prices on few macroeconomic 
indicators such as GDP and employment.  

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

The final updated NECP covers sufficiently the main reforms and investments of the Recovery 
and  Resilience  Plan  (RRP)  that  contribute  to  implementing  the  objectives,  targets,  and 
contributions of the Energy Union. Some measures included in the plan are more ambitious 
than those in the RRP, for example the increased target for electrolyser capacity to produce 
renewable hydrogen, set to 12 GW, above the 4 GW included in the hydrogen roadmap. 

The plan also improves upon the draft in providing further significant evidence on the outcomes 
to  achieve  with  the  reforms  and  investments  in  the  RRP,  beyond  the  main  initiatives  (e.g. 
renewable hydrogen). 

75 

 
 
 
 
 
3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

The Commission encourages Spain to ensure a timely and complete implementation of the final 
updated NECP. Spain is invited to pay particular attention to the following main elements:  

•  On ESR, implement in a timely manner the additional policies proposed in the plan as, 
while  Spain  is  projected  to  meet  its  2030  target,  a  significant  part  of  the  emissions 
reduction is driven by measures that are not yet fully in place. Pay particular attention to 
transport.  Ensure  robust  enforcement  of  the  requirements  of  the  Fluorinated  Gas 
Regulation. 

•  On  LULUCF,  strengthen  measures  to  meet  the  2030  target.  Consider  measures  that 
mitigate  climate  change  impacts  on  forests  and  promote  sustainable  land-use  practices 
such as combatting desertification, enhancing the resilience of forests to climate change, 
and implementing measures to increase carbon sequestration. 

•  On  adaptation,  further  operationalise  strategies  and  plans,  including  the  National 
Adaptation Plan 2021-2030. Detail how climate impacts on water availability affect the 
energy system, particularly in  relation to  renewable hydrogen  and  desalination. Special 
attention should be paid to potential cross-sectoral conflicts between energy production, 
agriculture, and urban water use, also across regions. Integrate climate risk assessments 
into  sectoral  plans,  focusing  on  energy  infrastructure  vulnerabilities,  such  as  floods, 
droughts  and heatwaves,  and reflect  this in  planning documents,  construction standards 
and in the design of energy systems. Ensure vulnerability assessments of energy networks 
and infrastructure are performed under different climate scenarios.  

•  Set a clear roadmap with specific measures to phase out fossil fuel subsidies. 
•  On  industry,  accelerate  efforts  to  decarbonise  hard-to-abate  industries.  Develop  and 
implement  a  CCUS  strategy  detailing  the  expected  storage  capacity,  injection  capacity 
targets,  and  sources  of  financing.  Emphasise  the  role  of  industry  in  mobilising  energy 
efficiency investments. 

•  Implement Spain’s planned “renewables acceleration areas”. These are key to ensure an 
appropriate  balance  between  accelerated  deployment  of  renewables  and  respect  for 
environmental and social imperatives. Consider local factors in NECP measures for the 
deployment of renewables. 

•  On energy efficiency, put in place measures to achieve the higher ambition for  energy 
efficiency by 2030. Implement further measures targeting the transport sector, which is 
projected to remain the biggest energy consumer in 2030. Streamline further the “energy 
efficiency  first”  principle  and  adopt  specific  monitoring  mechanisms  or  measures  that 
could support proper implementation.  

•  On buildings, ramp up the pace and depth of renovation of buildings in the non-residential 
building stock, introduce measures to address the worst performing segments, as well as 
including measures referred to smart/digital solutions in buildings. and measures related 
to the use of renewables (i.e. solar installations) for decarbonising heating and cooling. 

76 

 
 
 
 
 
•  On just transition, develop a more detailed and robust analysis of social and employment 
impacts  of  the  transition  in  a  comprehensive  just  transition  strategy  which  lists  all  the 
financial resources. 

77 

 
 
 
 
 
 
France 

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of France’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for net 
GHG removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 

Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

19.1% 
(SHARES) 
23% 
(target) 

National contribution for 
energy efficiency: 

2022: -23.7% 
2023: -25.7%86 

-47.5% 

Reported net 
removals of –
18.5 Mt CO2 eq. 
in 2022  

-6.69 Mt CO2 
eq. (additional 
removal 
target) 

NECP:  
-46.4% 
However, FR is 
expected to meet 
the 2030 target 
with ESR 
flexibilities 

Insufficient 
ambition:  
projected gap of 
13.4 Mt CO2 eq 
in 2030 

2023: 22.3% 

35%  
(accompanyin
g letter to the 
NECP) 
 41.4% 
(extrapolation 
of numbers 
included in the 
NECP) 

FR contribution 
of 35% - 41.4% to 
the EU target is 
below the 44% 
required pursuant 
to the formula of 
Annex II of the 
Governance 
Regulation87 

Primary energy 
consumption  

226.4 
Mtoe 

2023: 209.6 
Mtoe 

158.6 Mtoe 

FR primary 
energy 
consumption 
contribution of 
158.6 Mtoe is in 
line with the EED 
recast Annex I 
formula results: 
157.3 Mtoe (2020 
EU Reference 
Scenario) or 
158.66 Mtoe 
(Updated 

86 
The  ESR emissions  in 2022  are based on  2024  final  GHG inventory  reports, and  2023 emissions are 
based on 2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as 
set out in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions 
for 2021-2025 will only be established in 2027 after a comprehensive review. 
87 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’). 

78 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
Final energy consumption 

 137.9 
Mtoe 

2023: 130 Mtoe 

106.9 Mtoe 

Level of electricity 
interconnectivity (%)88 

8.5% 

2024: 5.6% 

15% 

Source: Eurostat; France’s final updated national energy and climate plan 

Reference 
Scenario) 

FR final energy 
consumption 
contribution of 
106.9 Mtoe is in 
line with the 
national 
contribution of 
106.9 Mtoe 
submitted by the 
Commission. 

FR is below the 
EU-wide 
interconnectivity 
target. 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In December 2023, the Commission published a thorough assessment of France’s draft updated 
NECP and provided recommendations89 for the preparation of the final updated NECP. France 
submitted its final updated NECP on 10 July 2024, soon after the deadline of 30 June 2024.90 

2.1  DECARBONISATION 

France  expects  to  decrease  total  GHG  emissions  (excluding  LULUCF)  by  50%  in  2030 
compared to 1990 (-51% including LULUCF), and to reach climate neutrality by 2050.  

2.1.1  Effort Sharing Regulation 
France has addressed recommendation 1. The final NECP provides sufficient details on how 
France will meet its ESR target of -47.5% by 2030 compared to 2005.  

The plan provides the same ESR projections as in the draft plan, showing that the existing and 
planned policies and measures will lead to a decrease of 46.4% in 2030 compared to 2005, a 
gap of 1.1 percentage points to the national ESR target. However, the plan states that, as the 
gap is within the margin of error of the models, and with the use of flexibilities, France expects 
to comply with the regulation. In 2023, GHG emissions from ESR sectors represented 79.9% 
of the total in France (expected to be 79.3% in 2030)91, with transport projected to represent 
the largest share. The ‘with additional measures’ (WAM) projected value for ESR in 2030 is 

88  Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2024). The 2020 figure 
also covers interconnectors with the neighbouring countries outside the EU. The 2030 level represents the general 
interconnectivity  target  of  15%.  The  2020  figure  covers  also  interconnectors  with  the  neighbouring  countries 
outside the EU. 
89 SWD(2023) 931 final, and Commission Recommendation of 18 December 2023, C/2023/9621. 
90 Article 14(2) of Governance Regulation. 
91 Share of total GHG emissions excluding LULUCF. Source: Commission calculations based on EEA data for 
2023 and on the French final updated NECP for 2030 (WAM scenario).  

79 

 
 
 
 
 
 
 
 
roughly  30%  lower  than  the  ‘with  existing  measures’  (WEM)  scenario,  hinting  that 
implementing  the  plan  will  require  a  significant  additional  effort.  France  has  LULUCF 
accounting  debit  gaps  under  the  LULUCF  Regulation,  which  are  projected  to  impact  its 
performance under the ESR. 

The final plan provides additional information on several policies and measures but could still 
benefit  from  a  clearer  description  of  their  scope,  timeline  and  expected  GHG  emission 
reduction.  The  plan  covers  all  ESR  sectors  comprehensively.  On  transport,  the  WAM 
projections  describe  a  significant  decrease  in  emissions  in  the  period  2022-2030,  with  the 
annual percentage decrease 7 times larger compared to the period 2015-2022 (from -0.64% to 
-4.5%).92 On agriculture, the plan lists a comprehensive set of additional measures expected 
to reduce emissions by 13% in 2030 (compared to 2021).  

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings, road transport and additional sectors (ETS2). The scenario projections account for 
ETS2 pricing, but do not quantify the impact of ETS2 in achieving the ESR target. 

2.1.2  LULUCF 
France has partially addressed recommendation 3. The LULUCF sector in France generates 
net removals, absorbing roughly 5% of the total GHG emissions in 2022. According to 2022 
figures, France has worsened its performance by 6.2 MtCO2eq compared to its yearly average 
in  the  2016-2018  reference  period.  According  to  the  LULUCF  Regulation,  France  has  to 
enhance its net removals by -6.69 Mt CO2eq in 2030 compared to the reference period. Based 
on  the  projections  provided,  France  will  have  a  gap  of  13.4  MtCO2eq  in  2030.  The  plan 
indicates additional policies compared to the baseline scenario, but these are not sufficient to 
achieve the LULUCF target.  

The plan provides information on how public funding (CAP) and private financing (Label Bas 
Carbone)  are  used  for  mitigation  in  the  agriculture  and  LULUCF  sectors.  The  final  plan 
clarifies  the  status  and  progress  in  ensuring  higher  tier  levels  and  geographically  explicit 
datasets needed to guarantee the robustness of net removal estimates. 

2.1.3  Carbon Capture and Storage 
France has addressed recommendation 2. The plan provides a comprehensive strategy on 
CCUS with financial incentives provided for both capture and storage. France aims to capture 
between 4 and 8.5 million tonnes of CO2 per year (Mtpa) by 2030. Out of the 2030 volumes, 
1.2  Mtpa  will  come  from  biogenic  sources  and  5.4  Mtpa  from  fossil  sources.  10%  of  the 
volumes to capture will be utilised. An assessment the available CO2 storage capacity started 
in early 2024 and is still ongoing. The plan recognises the importance of CO2 transport and 
refers to ongoing consultations with industry. 

2.1.4  Adaptation 
France has partially addressed recommendation 4. The plan refers to the National Plan for 
Adaptation  to  Climate  Change  (PNACC),  acknowledging  the  importance  of  integrating 
adaptation  planning.  It  partially  embeds  adaptation  policies  and  measures  in  the  relevant 
Energy Union dimensions.     

92 Compound annual growth rate. Data refers to whole transport sector, not only the part covered by ETS.  

80 

 
 
 
 
 
 
The plan contains a partial analysis of climate vulnerabilities and risks. It identifies several 
significant  risks  such  as  floods  and  heatwaves  related  to  energy  supply,  infrastructure, 
agriculture, soils and forestry. Nevertheless, risks associated with droughts and coastal erosion 
have not been considered.  The plan is also short of quantifiable assessment of impacts.  

The plan partially outlines the links to the specific Energy Union objectives and policies that 
adaptation  policies  and  measures  are  meant  to  support.  It  introduces  detailed  adaptation 
measures to promote climate-resilient infrastructure and energy supply, with a particular focus 
on  water  management  for  hydropower  and  nuclear  electricity  production.  Additionally, 
measures are envisaged for agriculture to reduce impacts of continuing droughts and increase 
carbon storage of agricultural soils. The plan extensively refers to adaptive forest management, 
with a focus on soil and biodiversity. However, the impacts and benefits of adaptation policies 
on other Energy Union objectives have generally not been quantified.    

The  plan  partially  addresses  the  consequences  of  climate  change  on  future  water 
availability.  It  lacks  a  fully  comprehensive  forward-looking  assessment  of  future  water 
demand and supply at the national scale, aligned with expected climate warming trajectories. 
It  also  does  not  adequately  address  possible  cross-sectoral  conflicts  such  as  with  energy 
production, agriculture, and residential water use in the face of growing water scarcity. 

2.1.5  Fossil Fuels 
France  has  partially  addressed  recommendation  18.  The  final  updated  NECP  includes 
commitments to phase-out coal from electricity production by 2027 with several conditions 
regarding security of supply. It also includes commitments to phase-down fossil fuels (coal, 
gas, and oil) consumption, aiming to halve it by 2030 and reduce it by a factor of 3 in 2035 
compared to 2012, but with no further details. 

The  plan  includes  a  commitment  to  phase  out  fossil  fuel  subsidies,  mentioning  that  France 
started to reduce fossil fuel subsidies by increasing excise duties on certain types of fuels (e.g. 
gasoil used in road haulage, petrol in aviation and non-road diesel, excluding agriculture) and 
is working towards further elimination of tax niches by 2030.  

2.2  RENEWABLES  

France  has  not  addressed  recommendation  5 93.  The  plan  does  not  include  an  explicit 
contribution of renewables to gross final energy consumption by 2030. An extrapolation of the 
numbers included in the plan yields to an increased range of 35% to 41.4%, which however 
remains below the formula level of 44% in line with Annex II of the Governance Regulation. 
The plan does not include an indicative trajectory towards 2030. The plan does not describe 
how France plans to cover the gap towards reaching its 2020 national binding renewables target 
and does not clearly explain how it intends to close the gap to the mandatory 2021 baseline. 

France has partially addressed  recommendation 6. Sector-specific projections, including 
the different renewable energy carriers for heating and cooling, district heating and cooling, 
industry, buildings, transport and innovative renewable energy sources for 2030 are included, 

93 France submitted its final updated NECP together with a cover letter that is considered an integral part of the 
Plan for the purpose of this assessment. 

81 

 
 
 
 
 
 
but  the  plan  does  not  confirm  whether  those  constitute  national  targets  to  achieve  the  sub-
targets  of  Directive  (EU)  2018/2001  (the  ‘revised  RED  II’)94.  The  plan  however  does  not 
include a specific target for renewable fuels of non-biological origin for industry in 2030. 

France  has  partially  addressed  recommendation  7.  The  final  plan  includes  additional 
information on policies and measures which are expected to be included in the multiannual 
energy  programming  law  (PPE).  This  includes  measures  to  support  renewable  electricity 
deployment  and  industrial  capacity  and  specific  measures  by  sector.  However,  the  plan 
includes few quantified details on expected impacts of, or allocated budget to, these measures, 
which  are  also  often  conditional.  France  has  provided  further  information  on  measures 
promoting the uptake of renewable hydrogen in industry. However, it does not contain further 
detail on the uptake of power purchase agreements. 

The plan describes the measures introduced by the Renewable Energy Acceleration Law, in 
particular  as  regards  planning  and  permitting,  including  some  basic  elements  regarding 
renewable  acceleration  areas.  It  also  gives  further  indications  on  policies  and  measures 
targeting renewable heating and cooling and the design of the obligation on fuel suppliers in 
the transport sector. 

France has addressed recommendation 8. The final plan provides additional information on 
biomass supply and consumption by sector for 2019 – 2030. It also includes an assessment of 
the domestic supply of forest biomass for energy purposes in 2021-2030 in accordance with 
the  strengthened  sustainability  criteria  of  the  revised  RED  II  and  an  assessment  of  the 
compatibility  of  the  projected  use  of  forest  biomass  for  energy  production  with  France’s 
obligations under the revised LULUCF Regulation, particularly for 2026-2030, together with 
national measures and policies to ensure such compatibility. Finally, the plan includes further 
measures to promote the sustainable production of biogas/biomethane and digestate. 

France has partially addressed recommendation 9. The final plan describes the process of 
transposition  of  the  revised  RED  II,  with  a  partial  timeline  for  the  adoption  of  legislation. 
However, the description lacks details on several aspects, in particular related to permitting, 
renewable acceleration areas and guarantees of origin. 

2.3  ENERGY EFFICIENCY DIMENSION 

France has partially addressed recommendation 10. France included the amount of energy 
consumption reduction of 85.9 ktoe95 per year to be achieved by all public bodies, which is 
also  disaggregated  by  sector  in  line  with  Article  5  of  Directive  (EU)  2023/1791  (‘EED 
recast’)96. France did not report the total floor area of heated and cooled buildings owned by 
public  bodies  to  be  renovated  yearly  nor  the  corresponding  yearly  energy  savings  to  be 
achieved, but it specified that it opted for the alternative approach. France indicated the total 
surface of the buildings owned by public bodies  to be subject of renovation to  nearly zero-

94 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 

2023/2413  

95 This figure is an initial estimation. 
96 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 

82 

 
 
 
 
 
 
energy to be 400 bn m2. France set out policies and measures to achieve the reduction of energy 
consumption from public bodies and the renovation of public buildings. 

France has partially addressed recommendation 11. France set out complete policies and 
measures to achieve the national contributions on energy efficiency but did not quantify the 
expected  energy  savings  and  the  contribution  for  each  of  the  reported  energy  efficiency 
measures. France specified how the Energy Efficiency First principle will be implemented and 
indicated  the  measure  “Environmental  Impact  Assessment  Process”  to  implement  it  and 
monitor  its  implementation  for  projects,  plans  and  programmes.  Moreover,  France  plans  to 
extend the scope of the assessment of Energy Efficiency First to both energy efficiency and 
energy sufficiency.  

France set out adequate measures to promote energy audits and energy management systems, 
including a requirement for energy audits for large companies every four years and plans to 
install energy management systems for businesses consuming more than 23.6 GWh annually. 

France has not addressed recommendation 12. France did not include updated milestones 
in comparison with the long-term renovation strategy (LTRS) 2020 and draft NECP 2023. The 
final updated NECP merely reminds the intermediate milestone of final energy consumption 
reduction to be achieved in 2030. While milestones are missing, the building sector is targeted 
by several relevant measures, but the quantification of their impact is not detailed. 

2.4  ENERGY SECURITY DIMENSION 

France  has  partially  addressed  recommendation  13.  The  final  plan  does  not  contain 
significant  additional  information  about  how  France  envisages  to  further  diversify  its  gas 
supply and continue encouraging gas demand reduction towards 2030. The plan does however 
contain a forecast  of the evolution  of natural  gas consumption, reaching  260 TWh in  2030, 
40% lower than 2012 levels, and 173 TWh in 2035 (WAM scenario). 

The plan provides more details on electricity flexibility needs and includes additional measures, 
such as a new support scheme for decarbonised  flexibility,  including  demand-side response 
and storage. The plan indicates an upcoming definition of national flexibility objectives. 

The plan includes an objective of returning to nuclear production of more than 400 TWh by 
2030,  constructing  and  commissioning  new  nuclear  reactors  after  2030,  and  strengthening 
uranium conversion and enrichment capacities. The plan does not provide information on the 
long-term  supply  of  nuclear  materials,  spare  parts,  or  maintenance  services.  The  long-term 
management of radioactive waste is addressed, and the plan describes measures to adapt the 
national nuclear waste management programme. 

The plan contains forecasts on oil consumption until 2050. It also describes the measures being 
investigated  to  ensure  the  adequacy  of  the  oil  infrastructure  in  the  long  run  (refineries,  oil 
stocks) with the expected oil demand decline and the move to lower-carbon alternatives.  

The final plan is substantially improved on climate adaptation, addressing climate impacts on 
the  electricity  system,  including  risks  to  the  network  and  the  effect  of  water  availability  in 
nuclear production. The plan includes a new list of dedicated objectives, including climate-
proofing new builds and reducing the climate vulnerability of hydroelectric and thermoelectric 

83 

 
 
 
 
 
production. However, the  section on the related  measures is  not  very detailed, and the plan 
mostly refers to actions planned for the PNACC, namely impact and hazard studies. 

2.5  INTERNAL ENERGY MARKET DIMENSION 

France has partially addressed recommendation 14. The plan does not define objectives or 
targets  concerning  market  integration  nor  provide  further  information  on  specific  measures 
facilitating  system  integration  of  renewable  electricity.  However,  France  includes  measures 
facilitating  the  integration  of  renewable  gases  in  the  existing  gas  network  in  line  with  the 
revised RED II.  

The  plan  provides  some  targets  to  improve  the  flexibility  of  the  energy  system  such  as  an 
objective  for  demand  response  in  the  multi-year  planning  (PPE),  but  there  are  no  specific 
objectives beyond 2028. The plan describes existing policies and measures and enable a non-
discriminatory participation of new flexibility services but does not indicate their impact nor 
their future development. Nevertheless, the plan elaborates on the quantification of flexibility 
needs and upcoming measures to develop demand side response through peak load tariffs or 
through a dedicated tender for demand response.   

The plan does not provide measures to develop more competitive wholesale markets or to phase 
out  measures  interfering  with  market  signals.  The  plan  mentions  the  post-Arenh  nuclear 
regulatory  framework  as  well  as  the  financing  of  new  competitive  nuclear  reactors  among 
measures to be developed, but it does not clarify how these measures will avoid interfering 
with market signals. 

France does not provide measures for a more competitive retail market or to increase the level 
of consumer empowerment for example through dynamic pricing or being engaged in valuing 
flexibility services. 

France has partially addressed recommendation 15. Based on existing indicators, France 
sets the objective to reduce energy poverty by 0,5% in 2030 (compared to 2022). The target 
lacks ambition but the approach is welcomed. 

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

France has addressed recommendation 16. The plan provides a comprehensive approach, 
including  targets  to  support  research,  innovation,  and  competitiveness  in  clean  energy 
technologies, establishing a pathway to 2030 and beyond to support the transition towards a 
net  zero  and  circular  economy.  The  plan  presents  policies  and  measures  to  promote  the 
development  of net-zero projects  including  those relevant  for energy intensive industries.  It 
describes  a  predictable  and  simplified  regulatory  framework  for  permitting  procedures  for 
manufacturing  and  simplified  access  to  national  funding.  Significant  policies  and  measures 
include financing of green industry through the mobilisation of public and private funds and 
speeding up procedures to reduce by half the time to locate industrial sites. Concrete objectives 
include:  the development  of two electrolyser gigafactories by 2030 for producing  hydrogen 
from renewable and low-carbon energy sources, together with a trajectory for hydrogen cost 
reduction; the development of manufacturing capacity of two million zero-emission vehicles 
by  2030,  and  associated  battery  gigafactories;  the  development  of  small  modular  nuclear 
reactors  by  2035;  as  well  as  concrete  roadmaps  for  the  decarbonisation  of  50  emissions 

84 

 
 
 
 
 
 
intensive  plants  in  seven  sectors.  The  plan  provides  detailed  policies  and  measures  for  the 
digitalisation of the energy system, the development of clean energy-related skills, and resilient 
and sustainable supply chains of key net-zero components and equipment.  

The plan acknowledges the importance of circular economy which is supported with concrete 
policies. 

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

France partially addressed recommendation 17. The plan estimates to EUR 110 billion the 
additional investment needs in 2030 (compared to 2021), covering all sectors. However, private 
and  public  investments  are  not  reported  separately.  The  assessment  is  based  on  a  sound 
methodology using a top-down model. The plan contains a brief overview at aggregate level 
of the main source of financial support for its implementation, without quantification. For some 
policies and measures, there is information on the amount of public funds available. However, 
this  information  is  not  provided  consistently,  and  it  is  not  linked  to  the  investment  needs 
figures. Hence, it is not possible to assess the existence of a potential financing gap, or how 
this would be filled.   

France has partially addressed the recommendation to provide a robust assessment of the 
macroeconomic impact of the planned policies and measures. The macroeconomic impact 
assessment does not integrate the findings of the accompanying report of the National Low 
Carbon Strategy (Stratégie nationale bas-carbone). 

2.8  JUST TRANSITION 

France has partially addressed recommendation 19. The final updated plan provides limited 
additional  information  on  the  analysis  of  the  social,  employment  and  skills  impacts  of  the 
energy and climate transition, and on the distributional impacts on vulnerable groups. While 
the plan includes several social measures and a quite comprehensive approach on skills in the 
context of the transition, measures addressing access and preservation of employment are not 
sufficiently addressed in the plan. The form of support, the impact of the initiatives, the target 
groups, and the financial resources (such as JTF, ERDF or national funds), are still not detailed. 
The commitments in the plan, albeit conditional, and the ones in the TJTP are aligned.     

The plan does not provide the analytical basis needed for the preparation of the Social Climate 
Plan, such as information on the estimated impact of ETS2 and the identification of vulnerable 
groups.  The  plan  does  not  explain  how  the  policy  framework  identified  in  the  plan  will 
contribute to the preparation of France’s Social Climate Plan nor how the consistency of the 
two plans will be ensured.  

2.9  PUBLIC CONSULTATION 

France has partially addressed recommendation 20. The plan describes a comprehensive 
approach  to  consult  stakeholders.  However,  the  process  was  not  specific  to  the  NECP,  as 
related to three energy and climate national documents that fed into the plan. The consultations 
were  organised  with  relevant  stakeholders,  national  and  local  authorities,  civil  society  and 
social partners, and took place at different moments (2 November 2021-15 February 2022, 22 

85 

 
 
 
 
 
October 2022-22 January 2023) with different methods (online, Youth Forum, working groups 
etc). 

The  plan  refers  to  an  online  summary  of  the  comments  received  during  some  of  these 
consultations. However, it does not describe in detail how the final plan integrated the inputs 
and changes suggested from stakeholders. 

2.10 REGIONAL COOPERATION 

France  has  partially  addressed  recommendation  21.  The  final  plan  lists  the  regional 
cooperation  fora  in  which  France  participates:  The  Pentalateral  Energy  Forum  (Penta),  the 
High-Level Group on North Seas Energy Cooperation (HLG NSEC) and the High-Level Group 
on Interconnectors in South-West Europe (HLG SWE). Although the plan does not mention 
specific actions, it sets out in detail the initiatives pursued in the Penta forum and the NSEC 
HLG.  For  the  former,  this  includes  collaboration  on  security  of  supply,  market  integration, 
decarbonisation,  and  hydrogen.  For  the  latter,  this  includes  hybrid  projects,  permitting, 
financing and long-term planning. Under the HLG SWE, France, Portugal and Spain signed a 
new Memorandum of Understanding (MoU) in December 2023 and agreed on an action plan 
towards 2030 with three priority areas for cooperation: increased electricity interconnections, 
offshore  infrastructure  and  RES  and,  lastly,  renewable  hydrogen.    The  plan  indicates  that 
France will consider the opportunity for joint projects as described in Article 9 of the revised 
RED II under these three fora. 

The final updated plan does not refer to progress nor to efforts to be undertaken for the signature 
of the three bilateral solidarity arrangements for the security of gas supply with its neighbours 
(Belgium, Germany, and Spain). 

2.11 ANALYTICAL BASIS 

 The  final  plan  is  based  on  solid  quantitative  analysis  and  the  methodologies  used  for 
projections and impact assessment are clearly explained and referenced. It embeds employment 
and skills impacts. Social, research and environmental outcomes are considered on a qualitative 
basis. The plan  includes updated projections compared  to the draft updated NECP, but  still 
does  not  provide  projections  under  the  planned  policies  and  measures  on  how  the  energy 
system will develop.  

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

The final NECP insufficiently covers the main reforms and investments of the Recovery and 
Resilience Plan (RRP) that contribute to implementing the objectives, targets and contributions 
of the Energy Union. The final updated NECP does not refer to energy renovation of public 
buildings (supported with EUR 6.4 billion in grants by the RRF), nor to the energy renovation 
of  social  housing  (EUR  500  million  in  grants  by  the  RFF),  which  are  relevant  climate  and 
energy  reforms  and  investments  of  the  RRP  and  its  REPowerEU  chapter.  Some  of  the 
investments and reforms addressed in the final NECP have not been adequately recognized as 
part of the RRP, such as investments related to the decarbonation of the industry, support to 
hydrogen, or the MaPrimeRenov scheme. 

86 

 
 
 
 
 
3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

The Commission encourages France to ensure a timely and complete implementation of the 
final updated NECP. France should pay particular attention to the following main elements: 

•  On  ESR,  implement  additional  policies  in  a  timely  manner,  as  even  though  France  is 
expected to meet its ESR target with the use of available flexibilities, a significant part of 
the emissions reduction is driven by measures that are not yet fully in place.  

•  On LULUCF, further align wood harvesting rates with the need to preserve ecosystems’ 
capacity  to  remove  and  store  carbon.  Favour  the  long-term  use  of  bio-based  materials 
favouring harvested wood products over energy uses. This could be done by adopting a 
merit order for biomass use through the final Low Carbon National Strategy, and by putting 
in  place  concrete  measures  for  its  implementation.  Continue  the  incentive-based 
approaches  for  carbon  farming  under  Label  Bas  Carbone,  by  exploiting  any  possible 
synergy  with  the  Carbon  Removal  and  Carbon  Farming  Regulation  (Regulation  (EU) 
2024/3012). 

•  On  adaptation,  ensure  the  risk  assessment  adopts  a  more  quantitative  approach, 
identifying impacts both short-  and long-term, and establishing  clear, measurable long-
term targets. Consider in risk assessments coastal erosion, storms and floods beyond their 
impact on infrastructure, agriculture, forests and energy supply. Special attention should 
be paid to potential cross-sectoral conflicts between energy production, agriculture, and 
urban water use, ensuring a comprehensive approach to water management.  

•  Continue the commitment to phase out by 2030 the fossil fuel subsidies identified in the 
NECP.  Clarify  remaining  fossil  fuel  subsidies  and  provide  a  detailed  timeline  for  their 
gradual phase-out. 

•  On  industry,  closely  monitor  the  implementation  and  impact  of  the  measures  for 

decarbonisation included in the plan 

•  On renewable energy, take action towards reaching its 2020 national binding renewables 
target  and  to  maintain  the  mandatory  baseline  after  2020.  97    Submit  an  explicit 
contribution in terms of the share of energy from renewable sources in gross final energy 
consumption for 2030 and put in place measures to achieve the higher ambition for the 
deployment  of  renewables  by  2030  that  aligns  with  the  EU’s  collective  target  for 
renewable energy. 

•  On energy efficiency, investigate additional measures tackling the energy consumption of 
industry, while also ensuring consistent focus on transport, which is the most consuming 
end-use  sector  (34%  of  FEC  in  2022)  as  comparatively  few  measures  in  the  final  plan 
target the industry sector.    

•  On  buildings,  ramp  up  the  pace  and  depth  of  renovations.  Ensure  the  stability  of  the 
national schemes “Ma PrimRenov” since predictability is key to mobilize stakeholders in 
the national renovation activity. 

97 In line with Article 32(4) of Governance Regulation. 

87 

 
 
 
 
 
 
•  Further develop  and implement  a framework that promotes  energy system integration 
which accommodates variable renewable energy across sectors, particularly in buildings 
and industry. Further promote corporate power purchasing agreements  

•  On  nuclear  energy  ensure  long-term  supply  of  nuclear  materials,  spare  parts  and 

maintenance services.  

•  Adopt  a  more  comprehensive  just  transition  strategy  that  includes  preservation  of 

employment and allocates appropriate financial resources.  

88 

 
 
 
 
 
 
 
 
 
 
 
Croatia 

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Croatia’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

2022: +0.1% 
2023: -9.9%98 

-16.7% 

NECP:  
-21.3% 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for 
additional net GHG 
removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 

Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

National contribution for 
energy efficiency: 

2022: Reported 
net removals of 
-4,9 
 Mt CO2 eq.  

- 0.6Mt CO2 
eq. (additional 
removal 
target) 

31.0% 
(SHARES) 
20% 
(target) 

2021: 31.3% 
2022: 28.1 
2023: 28.1 

42.5% 

Primary energy 
consumption  

10.7 Mtoe 

2022: 8.30 Mtoe 
2023: 8.54 Mtoe 

8.050 Mtoe 

Final energy consumption 

7 Mtoe 

2022: 6.89 Mtoe 
2023: 7.11 Mtoe 

5.88 Mtoe 

98 The ESR emissions for 2022 are based on Croatia corrected inventory data that was submitted in April 2024, 
which  is  reflected  in  the  European  Environment  Agency’s  Trends  and  projections  in  Europe  2024.  The  ESR 
emissions for 2023 are based on approximated inventory data. However, the final ESR emissions for 2022 and 
2023 will only be established in 2027 after a comprehensive review. 
99 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’).  

89 

Insufficient 
ambition based on 
projections: A gap 
of 2 
 Mt CO2 eq 
compared to the 
2030 target 

HR contribution 
of 42.5% is 
slightly below the 
44% required 
according to the 
formula set out in 
Annex II of the 
Governance 
Regulation99. 

HR primary 
energy 
consumption 
contribution is 
8.05 Mtoe. EED 
recast Annex I 
formula results: 
6.83 Mtoe 

HR final energy 
consumption 
contribution of 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
Level of electricity 
interconnectivity (%)100 

52.0% 

2024: 36.7% 

15% 

Source: Eurostat; Croatia’s final updated national energy and climate plan 

5.88 Mtoe is in 
line  with the 
national 
contribution of 
5.88 Mtoe 
submitted by the 
Commission. 

HR surpasses the 
EU-wide 
interconnectivity 
target 

2  CONSISDERATION OF COMMISSION RECOMMENDATIONS ON 

DRAFT NECP UPDATE 

In  December  2023,  the  Commission  published  a  thorough  assessment  of  Croatia’s  draft 
updated  NECP  and  provided  recommendations101   for  the  preparation  of  the  final  updated 
NECP. Croatia submitted its final updated NECP on 31 March 2025, nine months after the 
deadline of 30 June 2024.102 

2.1  DECARBONISATION 

Croatia  expects  to  decrease  total  GHG  emissions  (including  LULUCF  and  excluding 
international aviation) by 42% in 2030 and by 73% in 2040 compared to 1990.  

2.1.1  Effort Sharing Regulation 
Croatia addressed  recommendation  1 on reaching the target under the ESR.  The final 
NECP provides sufficient details on how Croatia will meet its ESR target of 16.7% by 2030 
compared to 2005.  

The plan provides updated projections that mark an improvement compared to the draft plan, 
showing that the existing and planned policies and measures will lead to a decrease of -21.3% 
in  2030  compared  to  2005,  an  overachievement  of  4.6  percentage  points  compared  to  the 
national ESR target. In 2023, GHG emissions from ESR sectors represented 71% of the total 
in Croatia (expected to be 66% in 2030)103, with transport representing the largest share. The 
WAM  projected  value  for  ESR  in  2030  is  roughly  14%  lower  than  the  WEM,  hinting  that 
implementing the plan will require a significant effort.  

100 Calculated by the European Commission based on the ENTSO-E data (Winter Outlook 2024). The 2020 figure 
covers also interconnectors with the neighbouring countries outside the EU. The 2030 level represents the general 
interconnectivity target of 15%. 
101 SWD(2023) 915 final, and Commission Recommendation of 18 December 2023, C/2023/9605. 
102 Article 14(2) of Governance Regulation. 

103 Total GHG excluding LULUCF. Source: Commission calculations based on EEA GHG emission inventories. 

90 

 
 
 
 
 
 
 
 
The final plan has complemented the information on the policies and measures provided in the 
draft but could still benefit from a clearer description of their scope, budget, timeline and, where 
possible, expected greenhouse gas reduction impact.   

For transport, the WAM projections describe a significant decrease in emissions in the period 
2022-2030 compared to the 2015-2022, with the annual percentage change going from +1.8% 
to -1.7%.104 The plan includes a variety of measures, including co-financing the purchase of 
new alternative fuel vehicles and the development of alternative fuel infrastructure. This is very 
relevant as the share of newly registered electric cars was lower than 5% in 2023, one of the 
lowest  in  EU.  The  plan  does  not  provide  quantified  targets  for  the  deployment  of  electric 
vehicles, nor on the related charging infrastructure.  

For buildings, the WAM projections describe a decrease in emissions, with the average annual 
percentage decrease going from -0.2% in the period 2015-2022 to -0.9% in the period 2022-
2030.105 See also sections 2.2 and 2.3. 

The  plan  refers  to  the  introduction  of  the  emission  trading  system  for  fuel  combustion  in 
buildings,  road  transport  and  additional  sectors  (ETS2).  The  scenario  projections  do  not 
explicitly account for the effect of ETS2, and do not clearly quantify the impact of ETS2 on 
the ESR target. 

On agriculture, the plan describes a stagnation in emission in the period 2022-2030. On waste 
and F-gases, the projections show a significantly declining trend in emissions. 

2.1.2  LULUCF 
Croatia  has  partially  addressed  recommendation  3.  The  LULUCF  sector  in  Croatia 
generates  net  removals,  absorbing  roughly  18.9%  of  the  total  GHG  emissions  in  2022. 
According to  the LULUCF Regulation,  Croatia has  to  improve its net  removals by  -0.6 Mt 
CO2eq in 2030 as compared to its yearly average in the 2016-2018 reference period. However, 
according to the latest reported 2022 figures, Croatia’s performance has worsened by 0.5 Mt 
CO2eq  compared  to  the  reference  period.  Moreover,  considering  its  projections  for  2030, 
Croatia will still have a gap of 2 Mt CO2eq in 2030. 

The plan provides some information, though insufficient, on how public funding (CAP, State 
aid) and private financing through carbon farming schemes are used to  reach the LULUCF 
target. The plan includes information on the status and progress in ensuring higher tier levels 
and geographically explicit datasets needed to ensure the robustness of net removal estimates. 
Overall,  based  on  the  available  information,  Croatia  does  not  design  sufficiently  effective 
policies to support the land sector and the achievement of the LULUCF target. 

2.1.3  Carbon Capture and Storage 
Croatia has partially addressed recommendation 2. The plan does not present a strategy on 
CCUS but provides a detailed description of CCUS activities, including an assessment of the 
expected availability of storage capacity and a partial assessment of the expected availability 
of transport capacity. Croatia targets an annual capture capacity of 0.367 Mtpa by 2028.  

104 Compound annual growth rate. 
105 Compound annual growth rate. 

91 

 
 
 
 
 
 
2.1.4  Adaptation 
Croatia has partially addressed recommendation 4. The plan refers to the Climate Change 
Adaptation Strategy in the Republic of Croatia until 2040 and the action plan to respond to the 
recommendation, acknowledging the importance of integrating adaptation planning. The plan 
is  rather  comprehensive  and  embeds  most  adaptation  policies  and  measures  in  the  relevant 
Energy Union dimensions. 

The plan contains an overall analysis of climate vulnerabilities and risks. It identifies several 
significant risks related s to floods, drought, water scarcity, forest fires and extreme weather 
events. The plan outlines adequate policies and measures to address these vulnerabilities and 
risks but is short of quantifiable assessment of impacts. 

The plan partially outlines the link to the specific Energy Union objectives and policies that 
adaptation policies and measures are meant to support. However, the impacts and benefits of 
adaptation policies on other Energy Union dimensions have generally not been quantified. 

The plan sets out some additional adaptation policies and measures to support the achievement 
of national objectives, targets and contributions under the Energy Union. For instance, the plan 
integrates  climate  change  adaptation  measures  in  the  use  of  renewable  energy  sources.  The 
plan partially addresses the consequences of climate change on future water availability and its 
implications on the energy sector. National and regional adaptation plans foresee integrating 
climate change aspects into water planning and water management. 

The  plan  refers  to  the  impact  of  the  projected  climate  change  induced  modification  of  the 
annual rainfall pattern and water availability on the operation of thermal water plants, hydrogen 
and biomethane production, pumped energy storage and hydropower generation. 

2.1.5  Fossil Fuels 
Croatia  has  partially  addressed  recommendation  19.  The  plan  includes  commitments  to 
phase-down coal for energy use by 2033 and explains the alignment with the Territorial Just 
Transition Plan (TJTP).  

The plan includes a commitment to conduct a comprehensive analysis of existing fossil fuel 
subsidies,  specifically  targeting  sectors  like  transportation,  agriculture,  and  fisheries.  
However, it does not indicate a clear phase out date nor a roadmap. 

2.2  RENEWABLES  

Croatia has partially addressed recommendation 5. Croatia did not raise the ambition of its 
national contribution of 42.5% to the Union’s binding renewable energy target for 2030 to at 
least 44% laid down in Article 3(1) of Directive (EU) 2018/2001 (the ‘revised RED II’)106 in 
line  with  the  formula  in  Annex  II  to  Governance  Regulation.  The  updated  trajectory  for 
achieving this contribution is outlined but it falls short of the trajectory calculated in line with 
the  EU’s  2030  renewable  energy  target.  The  plan  sets  sector-specific  renewable  share 

106 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  

92 

 
 
 
 
 
 
projections up to 2030, including electricity, heating and cooling, district heating and cooling, 
industry, buildings and transport. Additionally, Croatia sets a target for the transport sector. 

Croatia has partially addressed recommendation 6. Croatia provides a long-term plan for 
the deployment of renewable energy technologies, but not an estimated trajectory, over the next 
10 years, with an outlook to 2040. Croatia has not included an indicative target for innovative 
renewable energy technologies by 2030 in line with the revised RED II nor a specific target to 
contribute to the indicative sub target in buildings for 2030, but only an indicative trajectory. 
Croatia does not increase the projections included in the draft NECP to a level in line with the 
binding targets in heating and cooling nor increase the projections in the final plan to a level 
consistent with the binding targets. The final NECP does not confirm whether the projections 
contribute  to  the  binding  target  for  renewable  fuels  of  non-biological  origin  (RFNBOs)  in 
industry  by  2030,  nor  does  it  include  the  sub-target  for  advanced  biofuels  and  RFNBOs  in 
transport. 

Croatia has not addressed recommendation 7.  The final NECP does not include detailed 
and  quantified  policies  and  measures  that  would  enable  the  timely  and  cost-effective 
achievement of the national contribution to the Union’s binding renewable energy target of at 
least 42.5% in 2030, with the collective ambition to reach 45%. In particular, the plan lacks an 
explanation of how permitting will be  accelerated, or which renewable technologies will be 
covered  by  the  designation  of  ‘renewables  acceleration  areas’  with  simplified  procedures. 
Moreover, the plan does not specify how Croatia plans to support increased integration between 
electricity, and heating and cooling networks. 

Croatia  has  partially  addressed  recommendation  8.  The  final  NECP  lacks  information 
related to the projections for biomass supply, but when it comes to imports, it states that the 
import of solid biomass  is  relatively small  and amounts to  about  2%. The final  NECP also 
includes  some  further  information  when  it  comes  to  the  projected  demand  of  biomass. 
However, the final NECP does not include information on the source of forest biomass used 
for energy and an assessment of the domestic supply of forest biomass for energy purposes in 
2021-2030  in  accordance  with  the  strengthened  sustainability  criteria  of  Article  29  of  the 
revised RED  II.  In addition,  as no projected use  of forest  biomass  for  energy production is 
included, Croatia fails to provide an assessment of the compatibility of the projected use of 
forest biomass for energy production with Croatia’s obligations under the revised LULUCF 
Regulation. 

Croatia has not addressed recommendation 9. The final NECP does not provide an expected 
timeline  of  the  steps  leading  to  the  adoption  of  legislative  and  non-legislative  policies  and 
measures aimed at transposing and implementing the provisions of the revised RED II. Where 
related  policies  are  presented,  no  timeline  is  provided.  The  final  NECP  includes  a  general 
commitment to revise the existing legislative framework to “take into account the new goals 
and new obligations” defined in recently adopted EU legislation, without timeline or concrete 
implementation steps. 

2.3  ENERGY EFFICIENCY DIMENSION 

Croatia has partially addressed recommendation 10. Croatia includes an indicative national 
contribution of 5.9 Mtoe to the Union’s binding final energy consumption target for 2030 in 

93 

 
 
 
 
 
line  with  the  corrected  indicative  national  contribution  that  the  Commission  submitted  to 
Croatia in March 2024 pursuant to Article 4(5) of Directive (EU) 2023/1791 (‘EED recast’)107. 
Croatia  includes  an  indicative  national  contribution  of  8.1  Mtoe  to  the  Union’s  indicative 
primary energy consumption target for 2030. This contribution is not in line with Article 4 of 
EED Recast. There is still a gap of 17.9% compared to the target calculated with respect to the 
indicative results of the 2020 reference scenario, and a gap of 20.6% compared to the target 
calculated with respect to the indicative results of the updated reference scenario.  

Croatia does not include the amount of energy consumption reduction per year to be achieved 
by all public bodies. Croatia reported the total floor area of 414,000 m2 of heated and cooled 
buildings owned by public bodies, and specified that it opted for the alternative approach, but 
without updating the related targets in line with Article 6 of EED recast. Croatia set out some 
policies and measures to ensure the reduction of energy consumption from public bodies.  

Croatia  has  partially  addressed  recommendation  11.  Croatia  sets  out  comprehensive 
policies and measures to achieve the national contributions on energy efficiency but does not 
quantify the expected energy savings and contributions to achieve the targets for each measure. 
Croatia  only  quantifies  the  total  effect  of  energy  efficiency  and  transport  measures  in 
comparison  to  the  WEM  scenario.  Among  the  main  measures,  there  are  programmes 
supporting the renovation of family houses, the promotion of energy efficiency measures in 
manufacturing industries and the roll-out of energy management systems in the business sector.  
Croatia specifies how the energy efficiency first principle will be implemented and mentioned 
a specific implementation measure in the building sector.   

Croatia has not addressed recommendation 12. Similarly to the draft NECP, Croatia’s final 
NECP does not raise the ambition of the 2020 long-term renovation strategy (LTRS). The plan 
recalls some milestones of the LTRS such as the targeted renovation rates of residential and 
non-residential buildings and number of renovated buildings. There are five LTRS measures 
included  in  the  energy  efficiency  dimension  of  the  plan,  mainly  financial  programmes, 
targeting all the building subsectors. 

2.4  ENERGY SECURITY DIMENSION 

Croatia has partially addressed recommendation 13.  For gas, the final plan does not further 
explain  how  Croatia  intends  to  continue  encouraging  gas  demand  reduction  towards  2030, 
beyond  the  measures  to  promote  the  replacement  of  natural  gas  boilers  by  alternative 
technologies.  It  is  however  noted  that  the  plan  provides  some  forecast  for  the  evolution  of 
natural gas consumption, which is expected to increase from 101.7 PJ in 2021 to 107.3 PJ by 
2030, and then decrease to 97.3 PJ by 2040 (WEM scenario).  

To  improve  system  resilience,  the  plan  focuses  on  securing  the  natural  gas  supply  and 
strengthening  the  role  of  hydrogen.  Key  projects  include  the  expansion  of  the  Krk  LNG 
terminal and the reinforcing transmission network towards Slovenia and Hungary. The plan 
mentions infrastructure development with Albania, Montenegro, and Bosnia and Herzegovina 
but omits the impact on supply security. The infrastructure will transport hydrogen and mixes 

107 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 

94 

 
 
 
 
 
 
gases,  but  the  plan  does  not  mention  the  technical  and  policy  challenges  of  cross-border 
interoperability and blending causes.  

For  electricity,  Croatia  sets  an  objective  to  increase  the  flexibility  of  its  energy  system  by 
increasing  energy  storage  but  has  not  quantified  a  broader  target.  The  final  plan  includes 
targeted measures to improve electric power, gas and heat systems management with a specific 
target of 250 MW in new battery storage for 2030. It also refers to measure to modernise and 
digitalize the electricity system to integrate more electricity from renewable sources but lacks 
quantitative  targets.  Additionally,  the  plan  refers  to  further  improvement  of  north-south 
connection to ensure a smooth flow of energy to continental Croatia and further to other EU 
members.  

For the oil sector, the plan does not assess the adequacy of the oil infrastructure (pipelines, 
refineries and oil storage) in the long run with the expected oil demand decline and the move 
to lower-carbon alternatives. 

On nuclear energy, Croatia indicates that the operating life of the Krško Nuclear Power Plant 
in Slovenia (co-owned by Croatia and Slovenia) has been extended until 2043, and negotiations 
are underway to extend its operation beyond 2043.  The plan does not include information on 
measures taken to diversify and address long-term supply of nuclear materials, fuel, spare parts, 
and services, or on the long-term management of nuclear waste. The plan makes a reference to 
possible SMRs after 2035. 

The  final  plan  includes  a  succinct  identification  of  the  risks  (e.g.,  reduction  of  electricity 
production in hydroelectric power plants), and highlights the importance of water, notably on 
the resilience of energy systems to structural or seasonal water scarcity. However, it does not 
put  forward new policies  or measures beyond the reference to  the national  Climate Change 
Adaptation  Strategy  and  the  establishment  of  a  National  Centre  for  Adaptation  to  Climate 
Change. 

2.5  INTERNAL ENERGY MARKET DIMENSION 

Croatia has partially addressed recommendation 14. The final NECP does not put forward 
clear  objectives  or  targets  for  demand  response  to  enhance  energy  system  flexibility  and 
contains limited measures  to  address  the challenges of energy system  integration, including 
electro-mobility. The plan proposes to implement pilot projects for demand response measures 
on the distribution networks. While the projects have not commenced, the plan commits to a 
public call for the implementation of the pilot projects.   

The plan also lacks an assessment of flexibility needs and does not include concrete measures 
to support energy system integration of renewable electricity in line with Article 20a of the 
revised RED II. 

Croatia has partially addressed recommendation 15.  To develop an approach to address 
energy poverty, Croatia has assessed the number of people affected by energy poverty using 
the average of four indicators listed in EED recast. Croatia aims to increase its efforts to tackle 
both energy and mobility poverty based on the preparation of the social climate plan. The Social 
Climate Fund has been identified as a major financing source for these initiatives. Croatia has 
not set a reduction target for energy poverty in line with Governance Regulation and it does 
not mention energy poverty in the context of the analytical basis. In addition, the plan includes 

95 

 
 
 
 
 
 
some  measures  to  alleviate  energy  poverty  financed  by  the  Energy  Efficiency  Obligations 
Scheme (EEOS), which will focus on building renovation projects for citizens at risk of energy 
poverty. However, details on how this scheme will function are not provided. 

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Croatia has partially addressed recommendation 16. The plan includes national goals on 
R&D  spending  but  lacks  specific  targets  for  clean  energy  technologies  and  other  national 
strategies for 2029 (e.g. on Smart Specialization Strategy with a priority area in clean energy) 
and for 2050 (Hydrogen Strategy). Croatia outlines a pathway for 2030 and 2050 to support 
the decarbonisation of industry, focusing on CCUS, hydrogen, and circular economy, but lacks 
comprehensive  and  quantified  measures to  promote  the  development  of  net-zero  projects, 
especially in energy intensive industries. The plan does not describe how it will simplify the 
regulatory  framework  for  permitting  or  access  to  national  funding.  The  plan  includes 
information on policies and measures for the development of clean energy-related skills, for 
example  an  initiative  like  ‘Croskills’  training  centres  for  clean  energy  skills  but  lacks 
information on policies and measures for resilient and sustainable supply chains of key net-
zero components and equipment.  

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Croatia has not addressed recommendation 17. Though the plan provides an estimate of the 
investment needs of EUR 49 billion in 2024-2030, covering all sectors and including a detailed 
assessment at sub-sector level, the methodology used is still not explained. The plan confirms 
that at least EUR 11 billion will be covered by available public support (RRP, the Programme 
Competitiveness and Cohesion 2021-2027, Modernisation Fund, Social Climate Fund, other 
ETS  revenues).  Nevertheless,  how  the  remaining  part  will  be  financed  remains  unclear. 
Moreover, the plan still lacks measures to mobilise private investment. The methodology of 
the investment needs estimation is not explained.  

Croatia  has  not  addressed  the  recommendation  to  provide  a  robust  assessment  of  the 
macroeconomic  impact  of  the  planned  policies  and  measures.  The  modelling  exercise 
captures the impact of higher investment but does not account for the consumption and fiscal 
effects of the transition.  

2.8  JUST TRANSITION 

Croatia  has  partially  addressed  recommendation  20.  The  updated  NECP  improves  the 
analysis of the social,  employment and skills  impacts  of the  climate transition  but  does not 
sufficiently address the impact on the most vulnerable households. Moreover, the plan does not 
specify the form of support, the impact of initiatives or the resources available, except for the 
Just Transition Fund (JTF). 

The plan lacks the analytical basis needed for the preparation of the Social Climate Plan, such 
as information on the estimated impact of ETS2 and the identification of vulnerable groups. 
However, it recognizes the need to develop programs addressing energy and transport poverty 
and the necessity of clearly defining these concepts. The plan partially explains how the policy 

96 

 
 
 
 
 
framework identified in the NECP will contribute to the preparation of Croatia’s Social Climate 
Plan and how the consistency of the two plans will be ensured.  

2.9  PUBLIC CONSULTATION 

Croatia  has  not  addressed  recommendation  21.  Croatia  provided  very  little  information 
about the public consultation on the final NECP. The plan indicates that, from March to June 
2023,  Croatia  organised  thematic  workshops  on  several  topics  (i.e.  energy  efficiency, 
renewable energy sources and transport, energy security, agriculture, LULUCF and waste) and 
that more than 100 stakeholders participated. The plan also states that the national parliament 
and  the  local  and  regional  bodies  participated  in  the  preparation  of  the  draft  NECP.  .  It  is 
unclear whether a public consultation was carried out for the updated plan. The plan does not 
include a summary of the consultations and does not describe how the final plan integrates the 
inputs and changes suggested by the stakeholders, nor why some inputs were not considered.  

2.10 REGIONAL COOPERATION 

Croatia has not addressed recommendation 22. The plan describes some initiatives aimed 
at increasing Croatia’s engagement with neighbouring Member States and Energy Community 
Contracting Parties, but still does not refer to regional cooperation in the context of the Central 
and Southeastern Europe Energy Connectivity (CESEC) group, even if Croatia has been an 
active member and a beneficiary of this cooperation. The plan still does not identify common 
challenges and shared objectives in terms of interconnectivity, renewables, energy efficiency 
and internal market in a detailed way. The plan does not describe how Croatia plans to establish 
a framework for cooperation on joint projects with one or more other Member States by 2025, 
in line with Article 9 of Directive (EU) 2018/2001 as amended. 

The final plan does not refer to progress nor efforts to be undertaken as regards the signature 
of the two bilateral solidarity arrangements for the security of gas supply with its neighbours 
(Italy and Hungary). 

2.11 ANALYTICAL BASIS  

The plan provides a description of the analytical framework and includes projections of most 
of  the  required  variables.  It  assesses  the  impacts  of  planned  policies  and  measures  by 
comparing projections with a WEM scenario. The plan also provides a macroeconomic impact 
assessment  but  is  limited  to  an  analysis  of  the  impact  of  additional  investments  on  GDP, 
employment and gross value added.   

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

Croatia has partially addressed recommendation 18. Croatia’s final updated NECP  does 
not cover the main reforms and investments of the Recovery and Resilience Plan (RRP) that 
contribute to implementing the objectives, targets and contributions. The final updated NECP 
lacks  information  on  several  important  RRP  climate  and  energy  measures  relevant  to 
RePowerEU chapter  such as reforms  facilitating the uptake of renewable  energy sources or 

97 

 
 
 
 
 
renewable hydrogen, investments regarding energy efficiency in the water sector or climate 
adaptation/flood management.  

While some investments and reforms such as developing the gas transmission system correctly 
reference RRF, some others, such as improving electricity system management lack accurate 
references.  The  plan  continues  to  show  inconsistencies  flagged  in  the  draft  updated  NECP 
assessment regarding the RRP measure for a CO2 capture and storage pilot, which is no longer 
part  of  the  Croatia’s  RRP  and  has  been  replaced  with  studies  on  geological  CO2  storage 
potential. 

3 

 GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 
ENERGY AND CLIMATE PLAN 

The Commission encourages Croatia to ensure a timely and complete implementation of the 
measures needed to achieve its national climate and energy targets. Croatia is invited to pay 
particular attention to the following main elements: 

•  On ESR, implement in a timely manner the measures in the plan as a significant part of 

the emissions reduction is driven by measures that are not yet fully in place. 

•  On transport, implement  policies in  a more  comprehensive manner by simultaneously 
boosting sustainable urban transport, rail transport and the electrification of road transport. 
In parallel, implement measures which will increase the share of renewables in transport.    

•  On  LULUCF,  consider  additional  measures  to  meet  the  national  LULUCF  target. 
Complement the new forest management plan by outlining a clear and detailed pathway to 
reaching the LULUCF target, with a particular focus to the vulnerability to wildfires.  
•  On adaptation, assess quantitatively the relevant climate vulnerabilities and risks for the 
national objectives, targets, contributions, policies and measures in the different Energy 
Union  dimensions.  That  would  enable  better  outlining  and  quantifying  the  link  to  the 
specific Energy Union objectives and policies that adaptation policies and measures are 
meant to support. 

•  Develop a roadmap with specific measures to phase out fossil fuel subsidies. 
•  Speed up decarbonisation of industry  with  faster deployment  of renewables, hydrogen 

production and CCUS.  

•  As regards renewable energy, develop a comprehensive plan with dedicated measures to 
achieve the higher ambition for the deployment of renewables by 2030 that aligns with the 
EU’s collective target for renewable energy. 

•  On energy efficiency, set a national contribution for primary energy consumption in line 
with  ambition  required  by  the  EED  recast  and  put  in  place  sufficient  energy  efficiency 
measures  to  ensure  the  achievement  of  the  2030  targets.  Provide  further  details  on  the 
volume of private investments mobilised as well as a clear investment plan that anticipates 
the  investments,  including  their  disaggregation  by  dimension  and  the  split  between 
private/public,  to  support  the  implementation  of  the  plan  and  the  achievement  of  the 
targets. 

•  On buildings, ramp up the pace and depth of renovation rates in overall building stock; 
increase  ambition  for  residential  buildings  and  non-residential  buildings  for  the  years 
2030, 2040 and 2050 in the draft National Building Renovation Plan to be submitted in 

98 

 
 
 
 
 
December 2025; speed up the roll out of the national financing schemes by increasing the 
number of one stop shops. 

•  On energy security, develop separate pipeline systems for natural gas and hydrogen, as 

foreseen in the hydrogen and decarbonised gas package. 

•  Adopt  a  more  comprehensive  just  transition  strategy  that  addresses  the  impact  on 

vulnerable households and allocates sufficient funding. 

99 

 
 
 
 
 
 
 
 
 
 
Italy 

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Italy’s final updated NECP 

2020 

Progress  based 
on 
latest 
available data 

2030  national 
targets 
and 
contributions 

of 
ambition 

Assessment 
2030 
level 

2022: -20.9% 

2023: -22.3%108 

-43.7% 

NECP:-40.6% 

target 

Binding 
for 
greenhouse  gas 
(GHG) 
emissions 
to 
the  Effort 
2005  under 
Sharing  Regulation  (ESR) 
(%)  

compared 

-3.15 Mt 

CO2 eq. 
(additional 
removal 
target) 

2022: Reported 
net removals of 
-21 Mt CO2 eq. 

20.4% 
(SHARES) 

17% 
(target) 

2023: 19.6% 

39.4% 

target 
net 
under 

for 
Binding 
GHG 
additional 
removals 
the 
Regulation  on  Land  Use, 
Land  Use  Change  and 
Forestry (LULUCF) 

National 
target/contribution 
renewable energy: 

for 

Share  of  energy 
from 
renewable sources in gross 
final 
of 
energy (%) 

consumption 

National  contribution  for 
energy efficiency: 

Primary 
consumption  

energy 

158.0 Mtoe 

2023: 
Mtoe 

134.82 

123.3  Mtoe 

Insufficient 
ambition: 
projected gap of 
9.2 Mt CO2 eq in 
2030 

IT  contribution  of 
39.4%  is  slightly 
above 
the  39% 
required 
according  to  the 
formula  set  out  in 
Annex  II  of  the 
Governance 
Regulation109. 

IT primary energy 
consumption 
is 
contribution 
123.3  Mtoe. EED 
I 
recast  Annex 

108 
The  ESR emissions  in 2022 are based on  2024  final  GHG inventory  reports, and 2023 emissions are 
based on 2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as 
set out in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions 
for 2021-2025 will only be established in 2027 after a comprehensive review. 
109 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’). 

100 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
results: 
Mtoe 

or 
Mtoe 

formula 
112.16 
(Reference 
Scenario) 
111.18 
(Updated 
Reference 
Scenario). 

final  energy 

IT 
consumption 
contribution 
of 
101.70 Mtoe is not 
in  line    with  the 
national 
contribution 
93.05 
submitted  by 
Commission.   

of 
Mtoe 
the 

Final energy consumption 

124 Mtoe 

2023: 
Mtoe 

108.69 

101.70 Mtoe 

Level 
of 
interconnectivity (%)110 

electricity 

8.8% 

2024: 5.0% 

15% 

IT is below the 
EU-wide 
interconnectivity 
target. 

Source: Eurostat; Italys’s final updated national energy and climate plan 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In December 2023, the Commission published a thorough assessment of Italy’s draft updated 
NECP and provided recommendations111 for the preparation of the final updated NECP. Italy 
submitted its final updated NECP on 4 July 2024, just after the deadline of 30 June 2024.112 

2.1  DECARBONISATION 

Italy expects to decrease total GHG emissions (including LULUCF and excluding international 
aviation) by 49% in 2030 and by 60% in 2040 compared to 1990.  

2.1.1  Effort Sharing Regulation 

Italy has partially addressed recommendation 1. The plan provides insufficient information 
on how Italy will work to meet its ESR target of -43.7% by 2030 compared to 2005.  

The plan provides updated projections that mark an improvement compared to the draft plan 
but show that the existing and planned policies and measures will lead to a decrease of only 
40.6% in 2030 compared to 2005, 3.1 percentage points above the national ESR target. In 2023, 

110 Calculated by the European Commission based on the ENTSO-E data (Winter Outlook 2024).  The 2020 figure 
covers also interconnectors with the neighbouring countries outside the EU. The 2030 level represents the general 
interconnectivity target of 15%. 
111 SWD(2023) 917 final, and Commission Recommendation of 18 December 2023, C/2023/9607. 
112 Article 14(2) of Governance Regulation. 

101 

 
 
 
 
 
 
 
GHG emissions from ESR sectors represented 66.5% of the total in Italy (expected to be 70.1% 
in  2030) 113 ,  with  transport  projected  to  represent  the  largest  share.  The  ‘with  additional 
measures’ (WAM) projected value in 2030 is roughly 16% lower than the projections under 
the  ‘with  existing  measures’  (WEM)  scenario,  hinting  that  implementing  the  plan  and 
complementing it with additional measures to reach the target will require a significant effort. 
The plan mentions the availability of a surplus from LULUCF (5.75 Mt CO2 eq. for the period 
2021-2025) to help attain the ESR target. 

The  final  plan  complemented  the  information  on  the  policies  and  measures  provided  in  the 
draft but more details on scope, timeline and expected impact on GHG emissions would be 
useful. This is particularly the case for agriculture, whose emissions have stagnated in recent 
years.  For  what  concerns  transport,  the  WAM  projections  describe  a  drastic  decrease  in 
emissions in the period 2022-2030, with the average percentage decrease per year more than 5 
times larger than in the period 2015-2022 (from -2.14% to -5.16%).114 While the hierarchy of 
interventions on transport (Avoid – Shift – Improve) is correct and timely, the plan relies on a 
steep  take-up  of  electric  vehicles  (4.3  M  Battery-electric  vehicles  plus  2.2  Million  Plug-in 
hybrid  by  2030)  and  a  six-fold  increase  in  the  use  of  biofuels  by  2030,  which  is  hardly 
compatible  with  the  existing  fleet,  where  blends  are  limited  to  low  biofuels  concentration. 
Furthermore, the plan still refers to support for fossil fuelled vehicles and ships (CNG, LNG 
and LPG).  

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings,  road  transport  and  additional  sectors  (ETS2).  The  WAM  scenario  projections 
account for the effect of ETS2, but do not quantify its impact in achieving the ESR target. 

On agriculture, the plan does not provide sufficient detail in terms of funding and impacts of 
measures,  and  how  these  contribute  to  the  ESR  target.  Moreover,  the  projections  reflect  a 
stagnation in emission reductions, indicating a need for targeted policies and actions.  

The plan describes an effective approach to circular economy, including waste management 
and its impact on methane emissions, projecting a decline through reduced landfilling. It also 
details  the  historical  reduction  of  methane  emissions  within  the  energy  sector  and  outlines 
necessary  measures  to  sustain  this  trend.  In  addition,  the  plan  addresses  fluorinated  gas 
management, with projections indicating a continued decrease. 

2.1.2  LULUCF 
Italy  has  not  addressed  recommendation  3.  The  LULUCF  sector  in  Italy  generates  net 
removals,  absorbing  roughly  5%  of  the  total  GHG  emissions  in  2022.  According  to  the 
LULUCF Regulation,  Italy  has to  enhance  its  net  removals by  -3.2 Mt  CO2  eq. in  2030 as 
compared to its yearly average in the 2016-2018 reference period. However, according to the 
latest  reported  2022  figures,  Italy’s  performance  has  worsened  by  13.2  Mt  CO2  eq.  in 
comparison to  the reference period. Moreover, taking  into account  its projections for 2030, 
Italy will still have a gap of 9.2 Mt CO2 eq. in 2030. The plan indicates that for LULUCF there 
are no additional policies compared to the baseline scenario.  

113 Share of total GHG emissions excluding LULUCF. Source: Commission calculations based on the Italian final 
updated NECP  
114 Compound annual growth rate. 

102 

 
 
 
 
 
 
The plan does not provide sufficient information on how public funding (CAP, State aid) and 
private financing through carbon farming schemes are used to reach the LULUCF target. The 
plan  also  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. 
Overall, based on the available information, Italy does not design sufficiently effective policies 
to support the land sector and the achievement of the LULUCF target. 
2.1.3  Carbon Capture and Storage 
Italy  has  addressed  recommendation  2.  Italy’s  plans  with  regards  to  CCUS  are 
comprehensive, with complete legislation in place or under development. Support schemes are 
also under development. Italy is also working on cross-border flows of CO2.  

2.1.4  Adaptation 
Italy has partially addressed recommendation 4. The plan refers to the National Strategy for 
Adaptation to Climate Change and the National Climate Adaptation Plan (PNACC) to respond 
to the recommendation, acknowledging the importance of integrating adaptation planning. It 
partially embeds adaptation policies and measures in the relevant Energy Union dimensions. 
The plan contains a partial analysis of climate vulnerabilities and risks. It makes a reference 
to  the  climate  vulnerabilities  and  risks  assessment  in  the  PNACC,  and  identifies  several 
significant risks related to GHG emissions and energy efficiency. Nevertheless, risks associated 
with renewable energy and floods have not been considered. The plan is short of quantifiable 
assessment of impacts.    

The plan partially outlines the links to the specific Energy Union objectives and policies, 
that  adaptation  policies  and  measures  are  meant  to  support.  On  the  positive  side,  the 
preservation of water resources is mentioned as necessary to achieve the objectives of the GHG 
emissions  reduction.  The  related  actions  aim  to  improve  efficiency  of  water  infrastructure, 
effectiveness  of  planning  and  management  of  water  resources.  However,  the  impacts  and 
benefits  of  adaptation  policies  on  other  Energy  Union  objectives  have  generally  not  been 
quantified. The plan does not set out significant additional adaptation policies and measures 
to support the achievement of national objectives, targets and contributions under the Energy 
Union.  The  measures  for  nature-based  solutions  have  limited  impact  in  reducing  identified 
risks.  The  approach  to  address  the  investment  gap  is  also  insufficient  as not  sustained  over 
time.  

The  plan  partially  addresses  the  consequences  of  climate  change  on  future  water 
availability  and  its  implications  on  the  energy  sector.  It  however  lacks  a  comprehensive 
forward-looking assessment of future water demand and supply at the national scale, aligned 
with expected climate warming trajectories. It also does not adequately address possible cross-
sectoral conflicts such as with energy production, agriculture, and residential water use in the 
face of growing water scarcity. 

 Fossil Fuels 

2.1.5 
Italy has partially addressed recommendation 17. The plan includes a timeline to phase-
down fossil fuels for energy use, by January 2026 for continental regions, and January 2029 
for Sardinia. However, the timeline depends on the availability of sufficient alternative capacity 
for  which  Italy  has  tried  to  accelerate  the  necessary  authorisations.  The  plan  does  not 

103 

 
 
 
 
 
sufficiently  explain  the  alignment  between  the  NECP  and  the  TJTP  for  Sardinia,  nor  the 
timeline for the updated coal phase-out commitments.  

The plan includes a commitment to phase out fossil fuel subsidies, referring to the RepowerEU 
chapter of the national RRP, which includes the reduction of environmentally harmful subsidies 
by 2025. This is in line with the 2023 Country Specific Recommendation issued in the context 
of the European Semester. However, the plan does not set a roadmap. 

2.2  RENEWABLES  

Italy  has  partially  addressed  recommendation  5.  The  final  NECP  targets  a  39.4% 
contribution of renewables to gross final energy consumption by 2030, slightly lower than the 
draft target of 40.5%. The updated trajectory for achieving this contribution is outlined but it 
falls slightly short of the trajectory calculated in  line with the EU’s 2030 renewable energy 
target. Sector-specific projections, including the different renewable energy carriers for heating 
and  cooling,  district  heating  and  cooling,  industry,  buildings,  transport  and  innovative 
renewable energy sources for 2030 are included, but the plan does not confirm whether these 
constitute national targets.  

Italy  has  partially  addressed  recommendation  6.  The  plan  provides  some  additional 
information on policies and measures, including further facilitating permitting procedures, to 
achieve Italy’s national contribution to the Union’s renewable energy target, including the aim 
to put in place a consolidated legislative Energy Act (in adoption process) to simplify permit-
granting procedures including setting up a single digital gateway for permitting in line with 
Directive  (EU)  2018/2001  (the  ‘revised  RED  II’) 115 . The  plan  also  provides  additional 
information  on  measures  targeting  renewable-based  electrification  in  energy  intensive 
industries. Nevertheless, a linkage between the specific measures and their envisaged outcome 
is not always quantified. 

Some advancements on designation of “renewable acceleration areas” are described, however, 
not  all  of  them  are  conducive  to  meeting  the  revised  RED  II  targets,  namely  regarding  the 
designation  of  areas  non-suitable  for  renewable  energy  installations.  This  could  lead  to  a 
slowdown  of  new  installations  which  would  conflict  with  the  urgency  to  boost  renewable 
energy deployment.  

The  final  NECP  includes  projections  that  renewable  hydrogen  will  reach  a  54%  share  of 
industrial hydrogen consumed by 2030, in line with the revised RED II obligation. To this end, 
the plan lists measures to promote hydrogen use in the industry sector, although in a fragmented 
manner.  While  important  European  hydrogen  infrastructure  projects  and  overall  enabling 
framework for hydrogen are being developed, specific measures enabling renewable hydrogen 
trade are to be addressed. 

Italy  has  partially  addressed  recommendation  7.  The  final  NECP  provides  additional 
information on projections on bioenergy demand and supply disaggregated per sector (heat, 
electricity, transport) but lacks providing data for imports, the source of forest biomass used 

115 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  

104 

 
 
 
 
 
 
for energy and an assessment of the domestic supply of forest biomass for energy purposes in 
2021-2030  in  accordance  with  the  strengthened  sustainability  criteria  of  Article  29  of  the 
revised RED  II.  In addition,  as  no projected use  of forest  biomass  for  energy production is 
included, Italy fails to provide an assessment of the compatibility of the projected use of forest 
biomass for energy production with Italy’s obligations under the revised LULUCF Regulation. 
Finally,  Italy  includes  further  measures  to  promote  the  sustainable  production  of 
biomethane/biogas and its byproducts. 

Italy has partially addressed recommendation 8 as the plan lacks details on the procedural 
steps and timelines for most policies and measures. 

2.3  ENERGY EFFICIENCY DIMENSION 

Italy  has  partially  addressed  recommendation  9.  Italy  has  set  out  complete  policies  and 
measures to achieve the national contributions on energy efficiency but has not quantified the 
expected  energy  savings  and  the  contribution  for  each  of  the  reported  energy  efficiency 
measures. The energy efficiency first principle is acknowledged, with references to cohesion 
policies for implementation.  

Italy  has  specified  robust  energy  efficiency  financing  programmes  and  support  schemes  to 
mobilise private investments and co-financing as well as policy measures to promote the uptake 
of  energy  efficiency  lending  products  and  innovative  financing  schemes  such  as  Energy 
Performance  Contracts,  ESCOs  and  revolving  funds.  Italy  has  also  established  a  National 
Energy Efficiency Fund and has sufficiently detailed its role and functioning.  

Italy  has  set  out  measures  to  develop  the  necessary  infrastructure  for  high-efficiency 
cogeneration of district heating and cooling from waste heat and renewable energy sources, 
such as legislative updates setting stricter limits on the system emissions or obligations to use 
renewables  and.  incentives  to  develop  efficient  district  heating,  as  well  as  information  and 
training tools on digitalisation and smart metering. Italy has not submitted a comprehensive 
heating and cooling assessment.  

Italy has partially addressed recommendation 10. Italy has not included updated milestones 
after  the  long-term  renovation  strategy  (LTRS)  submitted  in  2020  and  merely  refers  to  the 
targeted annual renovation rates up to 2050.  The building sector is targeted throughout the 
NECP, in particular with financing and fiscal schemes that are expected to generate significant 
energy savings. However, the plan does not sufficiently describe the link between measures 
and financing, and renovation rates and energy savings. The measures described do not have a 
specific focus on the worst-performing buildings. 

2.4  ENERGY SECURITY DIMENSION 

Italy has partially addressed recommendation 11. In the gas sector, both the draft and final 
updated plans are substantial and complete, with for instance a detailed trajectory to phase out 
Russian gas by 2025, notably by increasing imports from Angola, Egypt, Congo, Qatar, and 
Algeria and by developing renewable electricity and biogas. 

105 

 
 
 
 
 
Several objectives  have  been added as regards constrained or interrupted electricity supply, 
notably related to interconnections, safe renewables’ generation and in terms of increasing the 
resilience of the energy system against impacts of climate change. Energy storage is mentioned 
as a way to manage the growth of non-dispatchable renewable generation, even if there is still 
no indicative objective for the deployment of storage capacities. Planned measures were also 
updated,  including  by  describing  new  rules  for  availability  remuneration  of  electricity 
production capacity.  

The plan describes the demand outlook for crude oil and oil products in detail. Recent capacity 
adjustments in the country’s refining sector are mentioned as well as several upcoming plans. 
However, it does not fully consider the expected post-2030 decrease in demand especially in 
the transport sector.    

The final plan has partially improved with a new list of dedicated objectives, including climate-
proofing new builds, and reducing the climate vulnerability of hydroelectric and thermoelectric 
production. However, the section on the related measures to achieve this is not very detailed. 

2.5  INTERNAL ENERGY MARKET DIMENSION 

Italy  has  partially  addressed  recommendation  12.  The  plan  details  projects  that  would 
increase electricity interconnection capacity with information on net transfer capacities and the 
status of projects. However, it does not set a target for electricity interconnection for 2030.  

Italy  does  not  quantify  flexibility  needs  but  includes  policies  and  measures  to  enhance 
flexibility.  Italy  will  promote  active  participation  of  distributed  energy  resources  such  as 
demand response and other flexibility resources and set new rules for demand response for the 
provision  of  ancillary  services.  Italy  also  aims  at  procuring  long-term  centralised  storage 
capacity, which will be made available to interested electricity market participants. The new 
measure  also  aims  at  optimising  grid  developments.  Italy  also  sets  the  strengthening  of  the 
forward  markets  (e.g.  PPAs  and  two-way  CfDs)  as  a  priority  with  the  aim  of  promoting 
investments in renewable generation capacity.  

In  terms  of  consumer  empowerment,  measures  focusing  on  energy  communities,  energy 
sharing and advisory services, Italy better empowers consumers thus making the market more 
competitive. 

Italy has partially addressed recommendation 13. The final plan gives a good overview of 
the  measures  in  place  to  address  energy  poverty  to  vulnerable  consumers  and  energy  poor 
households.  The Italian authorities are still working on the methodology to develop their own 
indicators adapted to the national context with the help of the EPIC (Energy Poverty Indicators 
Calculation)  Project,  launched  in  2023  and  financed  by  Eurostat.  However,  the  target  for 
reducing the number of households in energy poverty remains unambitious as the definition of 
energy poverty in the national legislation and related indicators is still being implemented. 

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2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Italy has partially addressed recommendation 14. The plan contains a specific breakdown 
of investment in research and innovation (R&I) for the energy sector for 2030 and 2050 but 
includes no specific policies and measures to promote and implement research in the priority 
technological  areas  for  2030  of  energy  storage,  renewables,  hydrogen  and  other  renewable 
fuels.  Similarly,  the  plan  lacks  competitiveness  targets  and  only  mentions  that  the  future 
measures on manufacturing of clean technologies will be based on NZIA and the CRMA. The 
key role of the circular economy in the transition and for competitiveness is clearly underlined 
and supported with several policies. 

The  plan  foresees  a  large  potential  in  helping  revitalising  nuclear  energy  with  the  possible 
deployment  of  8  GW  of  nuclear  capacity  by  2050  in  small  and  advanced  modular  reactors 
(SMRs/AMRs), and microreactors, out of which 0.4 GW are expected to be of fusion origin.  

The  final  plan  does  not  describe  a  predictable  and  simplified  regulatory  framework  for 
permitting procedures for manufacturing, nor how access to national funding will be simplified. 
The plan does not put forward clear measures to promote the development of net-zero projects, 
including those relevant for the energy intensive industries, but contains measures for regional 
cooperation and information on initiatives to bridge potential skills gaps for the transition.  

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Italy  has  partially  addressed  recommendation  15.  The  plan  provides  an  estimate  of  the 
additional  investment  needs  for  the  period  2024-2030  of  EUR  174  billion  compared  to  the 
WEM scenario. The assessment is based on a sound methodology, using a top-down model.  It 
covers the energy sector (electricity generation and networks, energy storages, electrolysers, 
and district heating), industry, vehicles and buildings. This estimate does not include transport 
infrastructure, nor policies for  GHG  emission reduction in  other  sectors. Private and public 
investment are not reported separately. The plan does provide a list of public support schemes 
and occasionally outlines their main sources of public financing. However, this is not done in 
a consistent way for all measures, and it is not linked to the investment needs figures, making 
it not sufficient to assess a potential financing gap, or how this would be filled.  

Italy has partially addressed the recommendation to provide a robust assessment of the 
macroeconomic  impact  of  the  planned  policies  and  measures.  The  macroeconomic 
assessment lacks a  comprehensive analysis  of key  dimensions as  consumption, government 
budget, and impact of carbon pricing.  

2.8  JUST TRANSITION 

Italy  has  partially  addressed  recommendation  18.  The  plan  provides  information  on  the 
impact of the transition to climate neutrality on employment but does not sufficiently address 
the impacts on the most vulnerable households. Moreover, the plan does not specify the form 
of support, the impact of initiatives or the resources available, except for the JTF and a minor 
amount from ETS revenues. The analysis focuses on the JTF and the Territorial Just Transition 
Plan. 

107 

 
 
 
 
 
The  plan  explains  why  Italy  expects  delays  in  the  coal  phase-out  compared  to  the  timeline 
provided  in  the  TJTP  for  Sulcis  Iglesiente  in  Sardinia,  mentioning  grid  security,  missing 
enabling infrastructure and the impact of Russian war of aggression in Ukraine. Italy commits 
to finalising the coal phase-out in the region in question between 2025 and 2028 and refers to 
concrete measures to protect workers through retraining and relocation.  

The plan lacks the analytical basis needed for the preparation of the Social Climate Plan, such 
as information on the estimated impact of ETS2 and the identification of vulnerable groups. 
The  plan  does  not  explain  how  the  policy  framework  in  the  NECP  will  contribute  to  the 
preparation of the Social Climate Plan nor how the consistency of the two plans will be ensured. 

2.9  PUBLIC CONSULTATION 

Italy  has  partially  addressed  recommendation  19.  Italy  organised  two  rounds  of  public 
consultations, including a wide range of stakeholders and a multi-level dialogue. The second 
round of consultations, based also on a preliminary version of the plan, started relatively close 
to the submission of the final plan (spring 2024). A Strategic Environmental Assessment was 
still ongoing at the time of the submission. The plan includes a summary of the outcome of the 
consultations, but only limited information is provided on what was discarded and why.     

2.10 REGIONAL COOPERATION 

Italy  has  partially  addressed  recommendation  20.  The  plan  includes  a  detailed  list  of 
initiatives aimed at increasing Italy’s engagement with neighbouring Member States, including 
in the context of the CESEC High-Level Group, but the plan still does not identify common 
challenges and shared objectives in terms of interconnectivity, renewables, energy efficiency 
and  internal  market  in  a  detailed  way.  Italy  does  not  provide  additional  information  on 
establishing the framework for cooperation on joint projects by 2025 in line with Article 9 of 
the revised RED II. The final plan refers to ongoing negotiations with Greece, Austria and with 
France but not with Croatia to sign bilateral solidarity agreements. 

2.11 ANALYTICAL BASIS 

The plan provides a description of the analytical framework, with projections reaching 2040. 
It  considers  economic,  employment  and  skills,  research,  innovation,  and  environmental 
impacts. Social and competitiveness outcomes are considered on a qualitative basis. Health, 
gender, and distributional impacts are not examined. The methodologies are described in detail. 
The final NECP includes an impact assessment of policies and measures.  

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

Italy  addressed  recommendation  16.  The  plan  covers  sufficiently  the  main  reforms  and 
investments of the Recovery and Resilience Plan (RRP) that contribute to implementing the 
objectives, targets, and contributions of the Energy Union. 

108 

 
 
 
 
 
3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN  

The  Commission  encourages  Italy  to  ensure  a  timely  and  complete  implementation  of  the 
measures  needed  to  achieve  its  national  climate  and  energy  targets.  Italy  is  invited  to  pay 
particular attention to the following main elements:  

•  Closely monitor the impacts of the policies included in the plan on emission reductions 
under  the  ESR,  increase  efforts  across  all  effort  sharing  sectors  and  explore  possible 
available flexibilities to ensure compliance with the ESR.   

•  Decrease  the  dependency  on  fossil  fuels  in  transport  and  buildings. Address  transport 
emissions through a conducive framework for EV deployment, in line with the ambitious 
target  presented  in  the  plan,  including  through  stable  fiscal  incentives  such  as  car 
ownership and company cars taxation based on CO2.  

•  On  LULUCF,  implement  additional  measures  given  the  widening  gap  to  the  target. 
Increase  monitoring  and  enforcement  of  sustainable  forest  management  practices  to 
address the risk of natural disturbances and improve the targeting and the commitments of 
existing interventions such as CAP measures on crop rotation and agroforestry.  

•  On  adaptation,  further  assess  future  water  demand  and  supply  under  different  climate 
scenarios  to  evaluate  impacts  on  the  energy  system,  with  particular  attention  to  cross-
sectoral  water  conflicts.  Elaborate  a thorough  assessment and mapping of climate risks 
covering  all  relevant  water-using  sectors  to  ensure  a  comprehensive  approach  to  water 
management.  

•  Set a clear roadmap with specific measures to phase out fossil fuel subsidies. 
•  On renewable energy, aim to achieve the more ambitious target of 40.5% as indicated in 
the draft plan. Address overreliance on imported renewable technologies and fuels (e.g., 
bioenergy and biogas imports), given the volatile nature of international biofuel markets 
and  the  potential  for  competition  with  food  production.  Increase  circularity,  supporting 
biofuel  targets  without  negatively  impacting  other  objectives,  such  as  those  under 
LULUCF.  

•  On energy efficiency, put in place measures to achieve the higher ambition by 2030 in 
line with the requirements of the EED recast. Set up further measures to improve energy 
efficiency in transport as well as in industry to achieve the required energy savings.  
•  Clarify plans on the development of nuclear energy, which has an important implication 
on the green transition and long-term investment decisions by industry, including on CCS, 
given the costs, the construction time, the complexity of the political processes and the 
potential need for regional cooperation.  

•  Develop  and  implement  a  framework  that  promotes  energy  system  integration, 
accommodates increased shares of renewable energy sources across sectors, particularly 
in buildings and industry.  

•  Promote  demand-response  and  flexibility  programs,  including  to  promote  energy 
storage  and  to  enable  consumers  to  adjust  energy  use  in  response  to  price  signals,  and 
consistency with energy efficiency measures to maximize their impact. 

109 

 
 
 
 
 
•  On industry, support decarbonisation through the uptake of renewables and waste heat, 
including  through  heat  pumps  or  heat  storage.  Foster  electrification  through  the  PPA 
market, leveraging on the experience with the first RES-H (FER-T) support scheme, and 
removing regional obstacles to RES deployment conflicting with the national decree on 
RES acceleration. 

•  On  buildings,  accelerate  the  pace  of  renovation  of  the  worst-performing  residential 
buildings  and  those  of  vulnerable  households.  Further  promote  the  electrification  of 
heating and deployment  of heat pumps by addressing the  unbalanced electricity-to-gas-
price ratio. 

•  Clarify how the development of innovative technologies and industries will be supported 
ensuring consistency with the SET-Plan and Horizon Europe to support the development 
of innovative industries in Italy. Detail planning of policies and measures to digitalise its 
energy system with a focus on grid infrastructure.  

110 

 
 
 
 
 
 
 
 
 
Cyprus 

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Cyprus’ final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

2022: +4.3% 
2023: +4.6%116 

-32% 

NECP:  
-25.9%  

2022: Reported 
net removals of 
-0.3 Mt CO2 eq.  

-0.06 Mt CO2 
eq. (additional 
removal 
target) 

Insufficient 
ambition based on 
projections: a gap 
of 0.02 Mt CO2 
eq  

2023: 20.2% 

33.2% 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for 
additional net GHG 
removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 

Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

16.9% 
(SHARES) 
13% 
(target) 

National contribution for 
energy efficiency: 

Primary energy 
consumption  

2.2 Mtoe 

2023: 2,52 Mtoe 

2.03 Mtoe  

Cyprus’s 
contribution of 
33.2% is slightly 
above the 33% 
required 
according to the 
formula set out in 
Annex II of the 
Governance 
Regulation117 

CY primary 
energy 
consumption 
contribution of 
2.03 Mtoe is  in 
line with the EED 
recast Annex I 
formula results: 
2.04 Mtoe 
(Reference 
Scenario) or 1.92 
Mtoe (Updated 

116  The ESR emissions in 2022 are based on 2024 final GHG inventory reports, and 2023 emissions are based on 
2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as set out 
in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions for 2021-
2025 will only be established in 2027 after a comprehensive review. 
117 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’) 

111 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Final energy consumption 

1.9 Mtoe 

2023: 1.87 Mtoe 

1.80 Mtoe 

Level of electricity 
interconnectivity (%)118 

0% 

2024: 0% 

15% 

Source: Eurostat; Cyprus’ final updated national energy and climate plan 

Reference 
Scenario) 

CY final energy 
consumption 
projection of 1.80 
Mtoe is in line 
with the national 
contribution of 
1.81 Mtoe 
submitted by the 
European 
Commission. 

CY  is  below  the 
EU-wide 
interconnectivity 
target. 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In December 2023, the Commission published a thorough assessment of Cyprus’ draft updated 
NECP  and  provided  recommendations 119  for  the  preparation  of  the  final  updated  NECP. 
Cyprus submitted its final updated NECP on 19 December 2024, almost six months after the 
deadline of 30 June 2024.120 

2.1  DECARBONISATION 

Cyprus  expects  to  increase  total  GHG  emissions  (including  LULUCF  and  excluding 
international aviation) by 1% in 2030 compared to 1990 and decrease by 39% by 2040.  The 
final updated plan indicates that Cyprus has a national target of net zero emissions by 2050. 

2.1.1  Effort Sharing Regulation 
Cyprus  has  partially  addressed  recommendation  1.  The  final  NECP  does  not  provide 
sufficient details on how Cyprus will meet its ESR target of 32% by 2030 compared to 2005. 
The plan provides updated projections that mark an improvement compared to the draft plan 
but showing that the existing and planned policies and measures will lead to a decrease of only 
25.9% in 2030 compared to 2005, falling short by 6.1 percentage points from the national ESR 
target. ESR sectors represent 50% of total GHG emissions in 2022, (expected to be 46% in 
2030). The large difference between the WAM (-25.9%) and WEM scenarios (-3.8%) hint that 
implementing the plan will require a significant effort. The plan mentions that the possible use 
of flexibilities to reach the ESR obligations is currently being explored.  

118  Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2024). The 2030 level 

represents the general interconnectivity target of 15%.  

119 SWD(2023) 910 final, and Commission Recommendation of 18 December 2023, C/2023/9600. 
120 Article 14(2) of Governance Regulation. 

112 

 
 
 
 
 
 
 
 
The  final  plan  complemented  the  information  on  the  policies  and  measures  provided  in  the 
draft plan but could still benefit from a clearer description of their scope, timeline and, where 
possible, expected greenhouse gas reduction impacts. Transport represented the largest share 
of  ESR  emissions  in  2022  (46%),  mainly  due  to  private  car  use.  While  some  measures  are 
foreseen in the transport sector (e.g. biofuels, infrastructure and incentives for electric vehicles, 
improving public transport availability, incentivising cycling, etc), others are delayed until after 
2030  (e.g.  improving  public  transport  availabilities  through  launching  a  tram).  Regarding 
buildings,  the  plan  notes  the  challenge  of  lacking  administrative  capacity  to  support 
decarbonisation of buildings.  

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings,  road  transport  and  additional  sectors  (ETS2).  The  WAM  scenario  projections 
account for the effect of ETS2. The scenario projections do not clearly consider the impact of 
ETS2 in achieving the ESR target. 

On agriculture, the plan does not provide sufficient detail in terms of funding and impacts of 
measures,  and  how  these  contribute  to  the  ESR  target.  Moreover,  the  projections  reflect  a 
stagnation in emission in 2030, indicating a need for targeted policies and actions. On waste, 
the plan outlines several relevant policies and measures but fails to quantify their impact. 

On F-gases, the plan includes a collection campaign and destruction effort of refrigerants, as 
well as the preparation of an inventory of equipment but it is not clear if the collection campaign 
will be a recurring effort. The plan also lacks consideration of campaigns to train technicians 
and promote the uptake of heat pumps. 

2.1.2  LULUCF 
Cyprus  has  partially  addressed  recommendation  3.  The  LULUCF  sector  in  Cyprus 
generates net removals of -0.3 Mt CO2 eq., absorbing roughly 3.4% of the total GHG emissions 
in 2022. According to the LULUCF Regulation, Cyprus has to improve its net removals by -
0.063 Mt CO2eq in 2030 as compared to its yearly average in the 2016-2018 reference period. 
However, according to the plan, Cyprus is projected to have a gap of 0.02 Mt CO2eq in 2030. 
The plan indicates additional LULUCF measures compared to the baseline scenario.  

The plan provides sufficient information on how public funding (CAP, State aid) and private 
financing through carbon farming schemes are used to reach the LULUCF target. However, 
the  plan  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. 
Overall, based on the available information, Cyprus does design sufficiently effective policies 
to support the land sector and the achievement of the LULUCF target. 

2.1.3  Carbon Capture and Storage 
Cyprus has not addressed recommendation 2. The plan does not contain a comprehensive 
CCUS strategy. It does not identify the amount of CO2 emissions that could be captured on an 
annual basis, provide details on how any captured CO2 would be transported, or identify the 
overall CO2 storage capacity and injection volumes available by 2030. Nevertheless, Cyprus 
recognizes  the  significant  role  CCUS  can  play  in  reducing  emissions  from  hard-to-abate 
industries. The country is also considering the possibility of opening parts of its territory for 
the exploration of geological formations suitable for carbon storage sites. 

113 

 
 
 
 
 
2.1.4  Adaptation 
Cyprus has partially addressed recommendation 4. The plan refers to the Cypriot Strategy 
for Adaptation to Climate Change, and its ongoing review. However, it lacks for most parts 
adaptation policies and measures in the relevant Energy Union dimensions. The plan contains 
a partial analysis of climate vulnerabilities and risks.  

Even if a climate risk and vulnerability assessment has recently been prepared, covering 15 
sectors including energy, the plan is nevertheless short of quantifiable assessment of impacts.  

The plan partially outlines the link to the specific Energy Union objectives and policies, that 
adaptation policies and measures are meant to support, particularly for the research, innovation 
and competitiveness dimensions. However, the impacts and benefits of adaptation policies on 
other Energy Union objectives have generally not been quantified. The plan sets out additional 
adaptation policies and measures to support the achievement of national objectives, targets 
and contributions under the Energy Union, but those proposed for agriculture are insufficient, 
as  they  do  not  address  the  consumption  of  freshwater.  Measures  for  water  management 
(including  networks)  are  also  considered  insufficient  to  properly  address  the  leakage  of 
freshwater  during  transport  or  the  impacts  of  floods.  The  plan  does  not  address  the 
consequences  of  climate  change  on  future  water  availability  and  its  implications  on  the 
energy sector. 

2.1.5  Fossil Fuels 
Cyprus has not addressed recommendation 16. The plan states that Cyprus does not provide 
fossil fuels subsidies and hence does not provide a timeline for their phase- out121. However, 
the plan states that there are subsidies to oil prices, and that energy products and electricity are 
subject to excise duty in accordance with the Excise Duty Act No 91 (I) of 2004. 

2.2  RENEWABLES  

Cyprus has addressed recommendation 5. The final plan contains an increased contribution 
of 33.17% as a share of renewable energy in gross final energy consumption by 2030, based 
on WAM scenario. This contribution is slightly above the one resulting from the formula of 
Annex  II  of  the  Governance  Regulation  (of  33%).  Cyprus  also  provides  a  table  with  the 
indicative  trajectory  that  reaches  the  reference  points  for  2025  (23.8%)  and  2027  (26.3%) 
respectively,  which  are  above  the  trajectory  (22%  and  26%)  calculated  in  line  with  the 
increased EU Renewable energy target of for 2030. 

Cyprus has partially addressed recommendation 6. Sector-specific projections for 2030 are 
included, but the plan does not confirm whether those constitute specific targets to achieve the 
sub-targets  of  Directive  (EU)  2018/2001  (the  ‘revised  RED  II’) 122 .  Specifically,  Cyprus 
indicates that the share of renewables in electricity will reach 37.6%, in heating and cooling 
53.6%  and  in  transport  18.6%.  The  average  annual  increase  of  renewables  in  heating  and 

121 The Commission 2024 study and  Report on Energy subsidies in the EU identifies the existence of fossil fuel 
subsidies. 
122 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 

2023/2413  

114 

 
 
 
 
 
 
cooling is slightly below the level of the indicative top-ups of Annex IA for the period 2021-
25  (1.52%)  but  above  it  for  2026-2030  (1.78  ppt).  A  projected  share  for  renewable  energy 
industry of 27.98% for 2030 is included, mainly to be fulfilled by biomass and energy from 
waste to produce industrial heat in combination with solar electricity. The Plan does not include 
a target for district heating and cooling for the 2021-2030 period since Cyprus does not foresee 
its  deployment  before  2032.  Cyprus  does  not  indicate  a  specific  target  for  innovative 
technologies  but  aims to adopt  measures to achieve  at  least  5% of new  installed renewable 
energy capacity in 2030.  

Cyprus has partially addressed recommendation 7. Cyprus mentions that it has concluded 
the mapping of renewables acceleration areas and published the maps, but without specifying 
which technologies will be covered. Cyprus indicates that the legislation on the acceleration of 
permitting is pending, without giving further details. The plan includes additional information 
on  the  measures  planned  to  promote  energy  communities  and  renewable  self-consumption. 
However, the completion of legal framework with all the necessary elements is still pending. 
No  further  information  is  provided  on  renewable  power  purchase  agreements  except  the 
reference to the need for amending national electricity market legislation nor on the design of 
the obligation on fuel suppliers in the transport sector. 

Cyprus has partially addressed recommendation 8. Some information is included regarding 
the transposition of the permitting provisions of the revised RED II and the enabling framework 
on self-consumption and energy communities. However, no detailed timeline is provided for 
the adoption of measures implementing the targets for RFNBO in industry and the sub-target 
for advanced biofuels and renewable fuels of non-biological origin (RFNBOs) in transport by 
2030. 

2.3  ENERGY EFFICIENCY DIMENSION 

Cyprus  has  addressed  recommendation  9.  The  plan  includes  an  indicative  national 
contribution to the Union’s binding final energy consumption target for 2030 of 1.80 Mtoe 
for  final  energy  consumption.  This  contribution  is  in  line  with  Article  4  of  Directive  (EU) 
2023/1791 (‘EED recast’)123 or equal to the corrected indicative national contribution that the 
Commission submitted to Cyprus in March 2024 under Article 4(5) of that Directive. Cyprus 
included  an  indicative  national  contribution  to  the  Union’s  indicative  primary  energy 
consumption target for 2030 of 2.03 Mtoe for primary energy consumption, is in line with 
Article 4. 

Cyprus has partially addressed recommendation 10. The NECP does not include an updated 
ambition level to ensure a highly energy efficient and decarbonised national  building stock 
and to transform existing buildings into zero-emission buildings by 2050. The plan includes 
intermediate milestones for 2030 and for 2040 and milestones for the renovation of both non-
residential and residential buildings, including on energy saving. The plan details the impact in 
terms of energy savings of each new measures put forward and includes sufficient information 
on measures for buildings in terms of funding and costs and provided specific information on 
policies and measures addressing deep renovation, with focus on worst-performing buildings 

123 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 

115 

 
 
 
 
 
 
and vulnerable consumers, as well as decarbonisation of heating and installation of renewables 
in buildings. 

2.4   ENERGY SECURITY DIMENSION 

Cyprus has partially addressed recommendation 11. Cyprus does not have gas in its energy 
mix, nor does it have gas interconnections with other Member States. The final plan mentions 
the  objective  to  start  natural  gas  imports  by  2026  thanks  to  the  PCI  “CyprusGas2EU”, 
compared to the aim in the draft plan to start in early 2024. The delays are attributed to the 
pandemic and to the termination of the contract between the company ETHNV and the Cypriot 
government. According to the WAM scenario, natural gas consumption is expected to ramp up 
and reach 578 ktoe and make for approximately 27% of the primary energy mix (608 ktoe and 
26%  in  the  WEM  scenario).  The  plan  does  not  assess  the  compatibility  of  its  future  gas 
infrastructure or the ramp up of gas consumption with decarbonization objectives. 

The final plan indicates that an indicative target for energy storage has been postponed to a 
later stage. 

The plan does not assess the adequacy of the oil infrastructure (oil storage) in the long run with 
the expected oil demand decline and the move to lower-carbon alternatives.     

While  the  plan  refers  to  the  present  and  upcoming  new  Strategy  on  Adaptation  to  Climate 
Change  and  the  recently  executed  Climate  Vulnerability  and  Risk  Assessment,  it  does  not 
provide specific details on how this will contribute to enhancing the climate resilience of the 
Cypriot energy system.  

2.5  INTERNAL ENERGY MARKET DIMENSION 

Cyprus has partially addressed recommendation 12. The plan mentions that the electricity 
market  in  Cyprus  cannot  currently  support  either  flexibility  services,  demand  response  or 
aggregation. Cyprus has recently adopted some new legislative measures that make possible 
flexibility services for storage as well as cumulative representation and demand response, but 
most likely towards the end of the decade, and the plan does not refer to specific targets. The 
final plan does not provide information on specific measures to facilitate system integration of 
renewable electricity in accordance with Article 20a of the revised RED II.  

Furthermore,  the  plan  does  not  provide  information  regarding  the  development  of  a  more 
competitive retail energy market or on strengthening consumer engagement. Although the plan 
mentions some elements of market liberalization and regulatory changes, it does not clearly 
describe policies or concrete measures that would ensure greater competition among energy 
suppliers or increase consumer empowerment. 

Cyprus has partially addressed recommendation 13. The draft updated NECP includes an 
assessment  of  energy  poverty  outlining  measures  such  as  energy  efficiency  improvements, 
financial  support  through  the  Social  Climate  Fund,  and  the  Energy  Efficiency  Obligation 
Scheme  to  assist  vulnerable  households.  It  also  sets  a  national  reduction  target  to  reduce 
affected  households  by  10%  by  2030.  However,  though  the  financial  resources  and  social 
measures  are  outlined,  the  plan  could  further  detail  dedicated  funding  streams  and  how  the 
Energy Efficiency Obligations Scheme will address energy poverty.  

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2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Cyprus  has  partially  addressed  recommendation  14.  The  plan  includes  comprehensive 
approach, with specific targets to support research, innovation, and competitiveness in clean 
energy technologies, establishing a pathway to 2030 and 2050, but does not specify the support 
per technology. The plan describes measures to promote the development of net-zero projects 
including those relevant for the energy intensive industries. It describes how it will ensure a 
predictable and simplified regulatory framework for permitting procedures for manufacturing 
and  how  access  to  national  funding  will  be  simplified  where  needed.  The  plan  provides 
information on policies and measures for the development of clean energy-related skills and 
facilitate resilient and sustainable supply chains of key net-zero components and equipment. 
Relevant measures include the "Labour Force Training Programme for Knowledge and Skills 
related to the Green Economy", that is being implemented to address the skills gap, funded 
under the Recovery and Resilience Plan.  

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Cyprus addressed recommendation 15. The plan provides estimates of total and additional 
investment  needs  per  sector  with  a  breakdown  by  public  and  private  investments.  The 
assessment is based on a sound methodology, using a top-down model, complemented by a 
bottom-up approach. 

The  plan  does  not  elaborate  on  how  to  mobilise  private  investments,  nor  does  it  include  a 
comprehensive  description  of  the  financial  support  schemes  or  the  types  of  financial 
instruments.  The  plan  describes  planned  national  and  EU  sources  and  outlines  only 
occasionally the sources of funding at measure or project level.  

Cyprus provides a robust assessment of the macroeconomic impact of the planned policies and 
measures. The plan includes a quantitative assessment of sectoral impacts, on different socio-
economic variables. 

2.8  JUST TRANSITION 

Cyprus has partially addressed recommendation 17. The plan provides information on the 
impact of the transition to climate neutrality on employment but does not sufficiently address 
the impact on skills and the most vulnerable households. Moreover, the plan does not specify 
the form of support, the impact of initiatives or the resources available, except for the JTF. The 
analysis still focuses on the JTF.  

The  gradual  decarbonisation  of  Dhekelia  heavy  fuel  power  plant  is  mentioned  without 
indicating whether it will be aligned to the fossil fuel phase-down timeline in the Territorial 
Just Transition Plan (TJTP).  

The plan lacks the analytical basis needed for the preparation of the Social Climate Plan, such 
as information on the estimated impact of ETS2 and the identification of vulnerable groups. 
The plan only partly explains how the policy framework identified in the NECP will contribute 
to the preparation of Cyprus’ Social Climate Plan and how it will interact with other public 
funds, both from the EU and the state budget.  

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2.9  PUBLIC CONSULTATION 

Cyprus has partially addressed recommendation 18. Cyprus organised two rounds of public 
consultations  for  the  preparation  of  the  final  plans.  The  first  round  took  place  from  the 
publication of the draft in December 2023 to the publication of the final NECP in December 
2024. The plan notes that input was received from various groups, including companies and 
environmental organisations, and that it was assessed and taken into account in the final text. 
The second round was a formal public consultation on a preliminary version of the final NECP. 
The consultation lasted three weeks but was closed only one week before the publication of the 
final  NECP,  which  limited  the  possibility  to  fully  take  stakeholder  input  into  account.  It  is 
unclear how many stakeholders commented on the draft, as the plan only mentions a public 
presentation on the draft (on 3 December), attended by over 75 participants from the public, 
private and NGO sector.  

The  plan  includes  a  detailed  summary  of  the  outcome  of  the  consultations  and  how  these 
comments have been or will be addressed by the Government of Cyprus.  

2.10 REGIONAL COOPERATION 

Cyprus  has  not  addressed  recommendation  19.  The  final  updated  plan  does  not  provide 
further information on plans to establish a framework for cooperation with other Member States 
by 2025 in line with Article 9 of the revised RED II. 

2.11 ANALYTICAL BASIS 

The  plan  provides  a  description  of  the  analytical  framework  under  both  WEM  and  WAM 
scenarios, with projections primarily focusing on 2030, complemented by longer-term view of 
2050.  The  plan  also  includes  a  quantitative  impact  assessment  on  sectoral  basis,  which 
estimates the effect on and socio-economic variables. 

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

The  final  NECP  covers  sufficiently  the  main  reforms  and  investments  of  the  Recovery  and 
Resilience  Plan  (RRP)  that  contribute  to  implementing  the  objectives,  targets,  and 
contributions of the Energy Union.  

3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

The Commission encourages Cyprus to ensure a timely and complete implementation of the 
final  updated  NECP.  Cyprus  is  invited  to  pay  particular  attention  to  the  following  main 
elements: 

•  On ESR, implement additional policies towards meeting the 2030 target, increase efforts 
to reduce GHG emissions across all effort sharing sectors, particularly those geared towards 

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decarbonising  transport  and  reducing  passenger  vehicles.  Explore  flexibilities  to  ensure 
compliance with ESR obligations. 

•  On  adaptation,  identify  gaps  and  needs,  including  financial,  to  assess  the  feasibility  of 
implementing  the  revised  2017 Adaptation  Strategy  and  its  action  plan.  Consider  how 
climate risk assessments are used for policy and investment decisions, i.e. how national or 
regional/local  climate  risk  assessments  are  used  for  spatial  planning  and  what  factors 
hamper  their  use.  Continue  to  develop  adaptation  policies  and  measures  to  increase  the 
water resilience of key water-using sectors.  

•  Clarify existing fossil fuels subsidies along with a roadmap with specific measures for their 

gradual phase out. 

•  On renewable energy, accelerate deployment of renewables in heating and cooling and 
transport sectors, and put in place an effective framework for speeding up the RES permit 
granting  procedures  and  further  measures  in  support  of  self-consumption  and  industry 
decarbonisation.  

•  On energy efficiency, ensure and monitor proper implementation of the energy efficiency 

first principle.    

•  On  buildings,  ramp  up  the  pace  and  depth  of  renovation  in  the  overall  building  stock 
including  through  increasing  the  availability  and  accessibility  of  technical  assistance  to 
citizens  and  implementing  ambitious  reskilling  programs  to  address  construction  labour 
shortages. 

•  Develop  a  more  comprehensive  just  transition  strategy,  that  includes  vulnerable 

households as well as upskilling/reskilling and allocates sufficient funding. 

•  On grid development, speed up the implementation of the Great Sea Interconnector project 
to ensure its completion by 2030, given the importance of the project  to end the energy 
isolation of Cyprus and to decarbonize through the integration of more renewable energy. 

119 

 
 
 
 
 
 
 
 
Latvia 

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Latvia’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

2022: -1.9% 
2023: -4%124 

-17% 

NECP: -20.5% 

Reported net 
emissionsof  
4.9 Mt CO2 eq. 
in 2022 

-0.64 MT CO2 
eq. (additional 
removal 
target) 

42.1% 
(SHARES) 
40% 
(target) 

2023: 43.2% 

61% 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for net 
GHG removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 

Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

National contribution for 
energy efficiency: 

Primary energy 
consumption  

5.4 Mtoe 

2023: 4.27 Mtoe 

3.85 Mtoe 

Insufficient 
ambition: a gap of 
5.51 Mt CO2 eq 
compared to the 
2030 target 

LV contribution 
of 61% is in line 
with formula set 
out in Annex II of 
the Governance 
Regulation125. 

LV primary 
energy 
consumption 
contribution of  
3.85 Mtoe is not 
in line with EED 
recast Annex I 
formula results: 
3.73 Mtoe (2020 
EU Reference 
Scenario) and 
3.75 Mtoe 
(Updated 
Reference 
Scenario) 

124  The ESR emissions in 2022 are based on 2024 final GHG inventory reports, and 2023 emissions are based on 
2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as set out 
in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions for 2021-
2025 will only be established in 2027 after a comprehensive review. 
125 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’). 

120 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
Final energy consumption 

4.5 Mtoe 

2023: 3.90 Mtoe 

3.46 Mtoe 

Level of electricity 
interconnectivity (%)126 

42.1% 

2024: 67.0% 

15% 

Source: Eurostat; Latvia’s final updated national energy and climate plan 

LV final energy 
consumption 
contribution of 
3.46 Mtoe is in 
line with the 
national 
contribution of 
3.46 Mtoe 
submitted by the 
Commission. 

LV has surpased 
the EU-wide 
interconnectivity 
target 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In February 2024, the Commission published a thorough assessment of Latvia’s draft updated 
NECP and provided recommendations127 for the preparation of the final updated NECP. Latvia 
submitted its final updated NECP on 15 July 2024, two weeks after the deadline of 30 June 
2024.128 

2.1  DECARBONISATION 

Latvia  expects  to  decrease  total  GHG  emissions  (including  LULUCF  and  excluding 
international aviation) by 59% in 2030, by 72% in 2040 and 71% in 2050, as compared to 1990. 

2.1.1  Effort Sharing Regulation  
Latvia  has  largely  addressed  recommendation  1.  The  final  NECP  provides  sufficient 
information on how Latvia will meet its ESR target of -17% by 2030 compared to 2005. 

The  plan  provides  updated  projections  (not  available  in  the  draft  plan),  showing  that  the 
existing and planned policies and measures will lead to a decrease of 20.5% in 2030 compared 
to 2005, an overachievement of 3.5 percentage points compared to the national ESR target. In 
2022, GHG emissions from ESR sectors represented 83.3% of the total in Latvia (expected to 
be  84.4%  in  2030) 129 ,  with  transport  projected  to  represent  the  largest  share  (35.8%  in 
2030).  The ‘with additional measures’ (WAM) projected value for ESR emissions in 2030 is 
roughly  10%  lower  than  under  the  ‘with  existing  measures’  (WEM)  scenario,  hinting  that 
implementing the plan will require effort. 

126  Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2024). The 2030 level 
represents the general interconnectivity target of 15%. 
127 SWD(2024) 43 final, and Commission Recommendation of 23 February 2024, C/2024/1188. 
128 Article 14(2) of Governance Regulation. 
129 Share of total GHG emissions excluding LULUCF. Source: Commission calculations based on the Latvian 
final updated NECP.  

121 

 
 
 
 
 
 
 
 
The  final  plan  complemented  the  information  on  the  policies  and  measures  provided  in  the 
draft but still lacks clarity in terms of their scope, timeline and expected GHG reduction impact. 
The plan covers all ESR sectors comprehensively. For what concerns transport, the WAM 
projections describe a significant change of pace in emissions reduction in the period 2022-
2030 compared to the period 2015-2022 (average annual decrease from –0.04% to –3.06%). In 
comparison to WEM, this requires an additional decrease of 0.5 MtCO2e, i.e. roughly 20% of 
the WEM target in 2030 (3 MtCO2e).  

For agriculture, in the period 2005-2030, the projections show an increase of emissions by 
22.5%, suggesting that targeted measures are needed. The plan contains measures on methane 
emissions related to energy and other sources, as well as on emissions from N2O and F-gases.  

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings, road transport and additional sectors (ETS2). The scenario projections account for 
the effect of ETS2, but do not quantify the impact of ETS2 in achieving the ESR target.  

2.1.2  LULUCF 
Latvia has partially addressed recommendation 3. The LULUCF sectors in Latvia generate 
emissions, representing 49% of the total GHG emissions in 2022. According to the LULUCF 
Regulation, Latvia must enhance its net removals by -0.64 MtCO2eq in 2030 compared to its 
yearly  average  in  the  2016-2018  reference  period.  According  to  2022  figures,  Latvia  has 
significantly  worsened  its  performance  (by  6.5  MtCO2eq.)  in  comparison  to  the  reference 
period. This is largely due to increased logging and emissions from organic soils. Despite the 
introduction of numerous additional measures, Latvia still expects to have a gap of 5.51 Mt 
CO2eq in 2030. The proposed LULUCF measures do not sufficiently take into account the EU 
biodiversity objectives. 

The plan acknowledges the need for both public (CAP, State aid) and private finance to achieve 
Latvia’s LULUCF targets and details the financial need for individual measures.  

The plan contains limited information on the status and progress in ensuring higher tier levels 
and geographically explicit datasets needed to ensure the robustness of net removal estimates.  

2.1.3  Carbon Capture and Storage 
Latvia has partially addressed recommendation 2. The plan does not provide a strategy on 
CCUS, and states that Latvia does not expect carbon capture, storage, transport or reuse by 
2030.  Hence,  the  does  not  include  an  assessment  of  the  expected  availability  of  storage  or 
transport capacity, nor an estimation of emissions planned to be captured.  

2.1.4  Adaptation 
Latvia  has  partially  addressed  recommendation  4.  The  plan  refers  to  the  2030  Climate 
Change  Adaptation  Plan  (LPKPP)  to  respond  to  the  recommendation,  acknowledging  the 
importance  of  integrating  adaptation  planning.  However,  it  lacks  adaptation  policies  and 
measures for most of the relevant Energy Union dimensions.   

The  plan  contains  a  partial  analysis  of  climate  vulnerabilities  and  risks.  It  also  identifies 
several  significant  risks,  related  to  power  fluctuations,  power  outages,  infrastructure 
vulnerabilities and biodiversity degradation. However, it is short of a quantifiable assessment 
of  impacts.  Nonetheless,  it  recognises  the  importance  of  developing  a  comprehensive  risk 

122 

 
 
 
 
 
assessment, with the next set of assessments focusing on different aspects of the energy sector 
expected to be completed in 2025.    

The plan does not outline nor quantify the links to the specific Energy Union objectives and 
policies that adaptation policies and measures are meant to support. Nonetheless, it mentions 
that urban and industrial infrastructure should undergo climate risk assessments, integrating 
climate change criteria in planning and investments for adaptation.     

The  plan  sets  out  some  additional  adaptation  policies  and  measures  to  support  the 
achievement  of  national  objectives,  targets  and  contributions  under  the  Energy  Union.  It 
mentions  several  measures  from  the  LPKPP,  such  as  strengthening  economic  sectors  or 
adapting engineering systems and infrastructure to climate risks and extreme events. However, 
it  does  not  specify  how  these  measures  are  implemented.  Furthermore,  the  plan  provides 
insufficient details on the measures identified to assess their financing, implementation, timing 
and scalability.  

2.1.5  Fossil Fuels 
Latvia  has  partially  addressed  recommendation  19.  The  plan  includes  commitments  to 
phase-down by 2030 peat use for electricity and heat generation, industry and services, though 
they require the modification of relevant national legislation. The plan does not include clear 
commitments to phase out some fossil fuel subsidies. It does list some policies and measures 
to eliminate energy fossil fuel subsidies by 2030, but without indicating if these are the only 
fossil fuel subsidies remaining or when the rest will be phased out. 

2.2  RENEWABLES  

Latvia  has  addressed  recommendation  5.  The  plan  puts  forward  an  updated  national 
contribution for renewable energy of 61% in gross final energy consumption by 2030 (based 
on WAM scenario)130. This contribution is in line with the level based on the formula of Annex 
II  of  the  Governance  Regulation. The  updated  indicative  trajectory  to  reach  the  61% 
contribution  in  2030 is  provided with  a specific reference point for 2025 (47.3%)131, which 
however is below the trajectory (49%) calculated in line with the increased EU 2030 renewable 
energy target of 42.5%. No information has been provided on the 2027 reference point.  

Latvia has partially addressed recommendation 6. The final NECP indicates that Latvia will 
reach more than 80% of electricity generation from renewables by 2030 that aligns with the 
EU’s  collective  target  for  renewable  energy.  However,  the  plan  does  not  contain  any 
projections on technologies up to 2030 to demonstrate how the ambitious contribution will be 
achieved. The plan contains a target of 5% for deployment of innovative renewable energy 
technologies  by  2030.  The  plan  includes  the  updated  projections  for  the  renewable  energy 
shares for specific sectors notably 29% in transport, 65% in buildings, and 73.9% in district 
heating and cooling in 2030 (without indications whether waste heat is included). As regards 

131 Reference points of 18% by 2022, 43% by 2025 and 65% by 2027 pursuant to Article 4(a)(2) of Governance 

Regulation. 

123 

 
 
 
 
 
 
 
 
heating and cooling, Latvia will exceed the 60% share of renewable energy in the coming years 
and will be exempted from the binding increase in line with Article 23(2) of Directive (EU) 
2018/2001 (the ‘revised RED II’)132. Latvia has also included a target of 42% for renewable 
fuels of non-biological origin in industry by 2030. 

Latvia  has  partially  addressed  recommendation  7.  The  plan  includes  a  comprehensive 
chapter  on  policies  and  measures  with  impacts,  planned  investments  and  result  indicators 
provided for most of the policies. As regards accelerating permitting, Latvia indicates that no 
further  information  has  been  included  as  it  is  subject  to  the  transposition  procedure  of  the 
revised RED II. The mapping on renewables acceleration areas will be finalised by 21 May 
2025 in view of approval by the government in February 2026.  

The  plan  provides  information  on  planned  measures  to  promote  electrification  in  district 
heating and cooling, including on reducing the use of biomass in the sector after 2030, measures 
to gradually reduce fossil fuels in heating and cooling and industry sectors as well as the design 
of the supply obligation in the transport sector. Latvia plans to promote recovery of waste heat 
in district heating and cooling.  The plan explains that it currently does not promote the use of 
hydrogen in industry. No further information has been provided on promoting the uptake of 
power purchase agreements or measures using guarantees of origin.  

Latvia has partially addressed recommendation 8 where sustainable biomethane production 
measures are not considered, beyond biogas production.  

2.3  ENERGY EFFICIENCY DIMENSION 

Latvia  has  addressed  recommendation  10.  For  energy  efficiency,  the  plan  includes  an 
indicative national contribution of 3.46 Mtoe to the Union’s binding final energy consumption 
target equal to the corrected indicative national contribution that the Commission submitted to 
Latvia in March 2024. The plan includes an indicative national contribution of 3.84 Mtoe to 
the Union’s indicative primary energy consumption target but the contribution is not in line 
with Article 4 of Directive (EU) 2023/1791 (‘EED recast’)133134. There is still a gap of 3.2% 
compared to the target calculated with respect to the indicative results of the 2020 reference 
scenario, and a gap of 2.4% compared to the target calculated with respect to the indicative 
results of the updated 2020 reference scenario.  

Latvia has partially addressed recommendation 11. Latvia sets out complete policies and 
measures  to  achieve  the  national  contributions  on  energy  efficiency  such  as  an  energy 
efficiency obligation scheme and an obligation to ensure that the energy performance of data 
centres,  but  it  does  not  quantify  the  expected  energy  savings  and  the  contribution  for  each 

132 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  
133 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 
134 From  NECP  "Latvia  has  complied  with  Article  4(5)(3)  of  EED  recast  and  does  not  exceed  the  indicative 
national energy efficiency contribution calculated by the Commission to the EU binding final energy consumption 
target. Latvia has declared that the national contributions are determined on the basis of the 2020 EU Reference 
Scenario." However, it is important to note that the WAM (Target scenario) sets an ambition of 4.031 Mtoe for 
PEC. 

124 

 
 
 
 
 
 
energy efficiency measure135. The plan specifies how the energy efficiency first principle will 
be  implemented  through  measures  such  as  the  evaluation  of  the  planning  system  and 
assessments in legislative and spatial development planning documents. 

Latvia includes the amount of cumulative energy savings of 2.54 Mtoe to be achieved by 31 
December 2030 but it does not specify clearly how the annual savings rate and the calculation 
baseline  are  established  nor  include  quantification  of  the  savings  targeting  energy  poverty. 
Latvia sets out adequate measures to promote energy audits and energy management systems, 
determining energy efficiency obligations for the largest energy consumers and obliging the 
public sector and certain businesses to implement energy management systems.  

The plan does not specify robust energy efficiency financing programmes and support schemes, 
to mobilise private investments and additional co-financing. The plan specifies existing policy 
measures to promote the uptake of energy efficiency lending products and innovative financing 
schemes (such as Energy Performance Contracts and ESCOs).  

Latvia has partially addressed recommendation 12. The plan includes an updated ambition 
level to ensure a highly energy efficient and decarbonised national building stock and the target 
to transform existing residential and non-residential buildings into zero-emission buildings by 
2050  (without  setting  milestones  for  2030  and  2040).  Latvia  does  not  quantify  the  energy 
savings of each new measure put forward. The plan includes sufficient information on funding 
and costs and energy savings136 of the related measures. The plan includes specific information 
on policies and measures addressing deep renovation with focus on vulnerable consumers, and 
specific information addressing decarbonisation of heating and installation of renewables in 
buildings.   

2.4  ENERGY SECURITY DIMENSION 

Latvia has partially addressed recommendation 13. The final plan does not further explain 
envisaged  measures  to  pursue  the  diversification  of  gas  supply,  nor  does  it  provide  any 
projections for the evolution of natural gas consumption towards 2030.  

To strengthen resilience of the electricity system, a main priority is the connection of Baltic 
States to the Central Europe synchronous area in February 2025 and desynchronisation from 
Russia’s  system  frequency.  Another  important  step  is  to  increase  the  electricity  generation 
capacities with renewable energy sources.  

On energy storage, Latvia projects at least two pilot projects in large power plants by 2035 and 
up  to  60  MW  of  electricity  storage  in  residential  and  economic  sectors  by  2030,  although 
without setting a general objective for energy storage deployment. It also mandates storage or 
balancing solutions for facilities with variable power generation, such as hydrogen sites.  

135 The NECP states that the savings from the list of measures provided in section 3.2.1 contribute to the Art 8 
target (see section 3.2.4 in LV NECP). 
136 The  NECP  provides  information  on  sectoral  contribution  to  Article  8  energy  savings  target,  in  which  the 
contribution of the household sector is 22%, while the commercial and public sectors account for 20%. 

125 

 
 
 
 
 
 
The plan contains projections on oil consumption until 2040. However, it does not describe the 
measures taken to assess the adequacy of the oil infrastructure in the long run (ports, pipeline, 
oil stocks) with the expected oil demand decline and the move to lower-carbon alternatives.  

The plan mentions that the draft climate law will require an assessment every 10 years of the 
risks  and  vulnerabilities  of  climate  change  for  the  most  sensitive  sectors  to  input  a  policy 
planning  document  on  adaptation  to  climate  change  for  the  next  decade.  The  first  risk 
assessment for the energy sector is planned for 2024/2025.  

2.5  INTERNAL ENERGY MARKET DIMENSION 

Latvia has addressed recommendation 14. The plan provides clear targets to improve the 
flexibility  of  the  energy  system,  elaborating  on  the  quantification  of  flexibility  needs  and 
setting clear objectives for demand response and flexibility. The plan clearly outlines its goal 
of deploying the “OneNet” IT platform to support energy system flexibility services and Latvia 
highlights  that  over  99%  of  its  electricity  users  are  currently  covered  by  smart  electricity 
meters.  The updated final plan does not provide further information on specific measures to 
facilitate system integration of renewable electricity in accordance with the new Article 20a of 
the revised RED II. 

Latvia  provides  measures  to  develop  competitive  wholesale  markets  and  defines  forward-
looking  objectives  and  targets  concerning  market  integration.  Latvia  outlines  a  clear  set  of 
policies  and  measures  aimed  at  significantly  reducing  electricity  imports  and  becoming  an 
electricity  exporter  by  2030. These  goals  are  supported  by  a  series  of  actions  detailing  the 
implementation process, responsible institutions, deadlines for execution, budget allocations, 
and  the  resources  dedicated  to  each  step. Latvia  has  provided  clear  targets  to  improve  the 
electricity  interconnection  capacity  and  sets  out  the  objective  to  achieve  the  70% 
interconnection target by 2030 with related actions.  

Latvia’s plan outlines measures to strengthen consumer empowerment, including support for 
energy  production  prosumers  and  energy  communities,  but  primarily  for  their  self-
consumption  and  not  for  selling  or  other  uses  of  surplus  energy.  In  addition,  the  final  Plan 
describes  the  new  regulatory  framework  for  energy  communities  and  energy  sharing,  to  be 
adopted  by  the  end  of  2024.  It  also  sets  a  dedicated  financial  instrument  to  support  energy 
communities.  

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Latvia has partially addressed the recommendation 16. The plan includes some national 
objectives  in  research,  innovation,  and  competitiveness  to  deploy  clean  technologies, 
establishing a pathway until 2030 to support the decarbonisation of industry and promote the 
transition of businesses towards a net zero economy. Significant policies and measures include 
increased support for digitalisation in energy and climate, e.g. through the establishment of the 
European Centre for Digital Innovation and Regional Hubs. The plan does not elaborate on the 
role of circular economy for decarbonisation and competitiveness and contains few details on 
related policies.  

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Latvia is active in international and cross-border cooperation, for instance BalticSeaH2 project, 
which aims to create a large-scale cross-border hydrogen valley (ecosystem) around the Baltic 
Sea.  

The plan puts forward policies and measures to promote net-zero projects, for instance through 
regulatory sandboxes. It does not describe a predictable and simplified regulatory framework 
for  permitting  procedures  for  manufacturing,  or  how  access  to  national  funding  will  be 
simplified where needed. The plan provides detailed policies and measures for the development 
of clean energy-related skills, notably setting up a Hydrogen Centre of Excellence as part of 
the Skills Development Action. The plan also includes measures to facilitate open trade for 
resilient and sustainable supply chains of key net-zero components and equipment, such as the 
National Net Zero Technologies strategies for export-oriented production. 

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Latvia  partially  addressed  recommendation  17.  The  plan  provides  detailed  estimates  of 
investment needs for several policies across different sectors, indicating the financing sources. 
However, the plan does not detail how public investments will mobilise private investments, 
nor does it provide a breakdown for public and private investments.  

It is not clear whether the investment needs relate to a WEM or a WAM scenario, nor whether 
all policies up to 2030 are included in the assessment of investment needs. The information 
provided in  the plan is  not  sufficient  to  assess  a  potential financing  gap  with  respect  to  the 
investment  needs,  or  how  this  would  be  filled.  The  assessment  is  based  on  a  sound 
methodology, using a top-down model complemented with bottom-up estimates for all sectors.  

Latvia has partially addressed the recommendation to provide a robust assessment of the 
macroeconomic impact of the planned policies and measures. The assessment is very brief 
and does not include details, notably on GDP and employment. The impact on public finances 
is described. However, the plan does not clearly quantify the needs in term of public financing 
by 2030 and the effects on public spending. 

2.8  JUST TRANSITION 

Latvia has not addressed recommendation 21. The plan provides an insufficient analysis of 
the  social,  employment  and  skills  impacts  of  the  energy  and  climate  transition,  or  other 
distributional  impacts  on  vulnerable  groups.  The  plan  assesses  the  impact  of  policies  and 
measures on employment, but the analysis is not comprehensive. Emphasis is put on energy 
poverty without including information on the role of the social dialogue. 

The plan is not fully consistent with the Territorial Just Transition Plan (TJTP). The phase-out 
of fossil fuels excludes domestic appliances and is laid out in three steps: phasing out of solid 
fossil fuels (coal, peat, peat briquettes, shale) by 2030, of liquid fossil fuels by 2040 and of 
natural gas only starting in 2050. The plan does not mention the planned peatland restoration 
actions in the regions of Vidzeme, Latgale, Zemgale, and Kurzeme, while the commitments to 
phase  out  peat  for  energy  generation  by  2030  requires  the  modification  of  the  relevant 
legislation.  

The plan lacks the analytical basis needed for the preparation of the Social Climate Plan, such 
as information on the estimated impact of ETS2 and the identification of vulnerable groups. 

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The plan does not explain how the policy framework identified in the NECP will contribute to 
the preparation of Latvia’s Social Climate Plan nor how the consistency of the two plans will 
be ensured.  

2.9  PUBLIC CONSULTATION 

Latvia  has  partially  addressed  recommendation  22.  Latvia  organised  two  rounds  of 
consultations.  An  initial  consultation  organised  in  early  2024  led  to  over  50  meetings  with 
various stakeholders (e.g. NGOs, stakeholders from industry, experts, and social partners) to 
collect  proposals  and  objections.  Latvia  then  organised  a  public  consultation  with  social 
partners, but only on 12 June 2024.  

The  consultation  on  the  final  plan  started  close  to  the  submission  (15  July  2024),  and 
stakeholders were given 5 weeks. The plan describes stakeholder input from the consultation 
but does not clarify whether inputs were included in the final NECP. The plan does not include 
a summary of the outcome of the consultations, but a summary is available on the website of 
the Ministry of Climate and Energy. A Strategic Environmental Assessment was still ongoing 
at the time of the submission of the final NECP.  

2.10 REGIONAL COOPERATION 

Latvia has partially addressed recommendation 23. Latvia expanded regional cooperation 
with neighbouring Member States within the Baltic Sea area and within the BEMIP High-Level 
Group. Regional cooperation for infrastructure planning using the BEMIP format is described, 
and  Baltic  States  have  coordinated  their  measures  for  infrastructure  development  projects 
proposed  in  their  NECPs  to  assess  the  potential  impact  of  their  measures  on  neighbouring 
countries. However, in  the context of renewable  energy, Latvia does not  provide additional 
information in its final plan on establishing the framework for cooperation on joint projects by 
2025 in line with Article 9 of Directive of the revised RED II.  

2.11 ANALYTICAL BASIS 

Latvia has not addressed recommendation 20. The plan describes the analytical framework 
and  includes  projections  until  2040.  It  also  includes  an  assessment  of  planned  policies  and 
measures, including macro-economic, social and employment impacts. However, it lacks an 
impact assessment of additional policies and measures. 

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

Latvia has addressed recommendation 18. The plan covers sufficiently the main reforms and 
investments of the Recovery and Resilience Plan (RRP) that contribute to implementing the 
objectives, targets and contributions of the Energy Union. Although only a few RRP measures 
are explicitly referred to in the NECP text, Latvia has duly specified when RRF (co)financing 
is envisaged for wider policy actions covered by the NECP. The final updated NECP mentions 
the  reforms  included  in  the  reform  package  to  transform  the  energy  sector,  for  example  on 
energy communities and the net settlement system, but without referring to the RRP and the 
REPowerEU chapter. 

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3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

The Commission encourages Latvia to ensure a timely and complete implementation of the 
final  updated  NECP.  Latvia  is  invited  to  pay  particular  attention  to  the  following  main 
elements: 

• 

Implement in a timely manner additional policies towards its ESR target, as a significant 
part of the GHG emissions reduction is driven by measures that are not yet fully in place. 
Reconsider the uses of CNG/LNG for public transport that may go against decarbonisation 
objectives.  

•  On  LULUCF,  increase  monitoring  and  enforcement  of  sustainable  forest  management 
practices, and address emissions from organic soils by initiating large-scale rewetting of 
drained peatlands and promoting alternative income streams  for landowners through the 
development of paludiculture (the wet cultivation of crops on peatland). Invest into capacity 
building  and  programs  for  landowners,  forest  managers,  and  local  communities  on 
sustainable land use practices. 

•  On  adaptation,  ensure  that  the  next  risk  assessment,  planned  for  2025,  adopts  a  more 
quantitative  approach,  specifying  anticipated  impacts  and  establishing  clear,  measurable 
long-term  targets.  Consider  different  climate  scenarios  and  wide  range  of  climate  risks, 
including flooding, wildfires, drought, and variability in wind and solar energy. The risk 
assessment  should  describe  in  greater  detail  the  implementation,  financing,  scaling,  and 
timing of adaptation measures to ensure effective mitigation of climate risks.  

•  Clarify existing fossil fuel subsidies and provide a detailed timeline for their gradual phase-

out. 

•  Set specific milestones for renewable energy technologies for 2030 for wind and solar 
power to decarbonise the domestic electricity consumption with 100% renewable energy 
by 2030.  

•  Put in place an enabling framework to promote the uptake of power purchase agreements 
and  guarantees  of  origin.  Further  facilitate  energy  system  integration  by  increased 
demand side flexibility solutions and facilitate integration between electricity and heating 
and cooling networks.  

•  Swiftly  implement  the  planned  reforms  on  permitting  and  renewable  energy 
communities and advance with  cooperation on joint projects  with  other  Member States. 
Increase awareness amongst citizens about available measures promoting renewable energy 
and their wider system benefits. 

•  On  energy  efficiency,  put  in  place  measures  to  achieve  the  higher  ambition  for  energy 
efficiency  by  2030  for  primary  energy  consumption.  Set  further  measures  on  industry 
including an energy efficiency obligation scheme (EEOS) for substantial energy savings, 
and  other  supporting  measures  such  as  technical  assistance,  information  and  education 
measures to ensure higher energy savings. 

•  On transport, put in place additional regulatory measures, such as stricter standards for 
consumption  or  economic  incentives,  to  further  support  decarbonisation  as  transport  is 

129 

 
 
 
 
 
projected to become the end-use sector with the highest share of energy consumption (i.e. 
32%).  

•  On  buildings,  clarify  intermediate  milestones  for  building  renovations  for  2030  and 
2040, and for energy savings for the buildings stock. Put forward policies and measures 
addressing deep renovation of worst-performing buildings. 

•  Continue the development of a plan for peatland restauration in line with the agreements 

in the Territorial Just Transition Plan of Latvia.  

•  Adopt a more comprehensive just transition strategy that includes a robust analysis of 
social, employment and skills impacts which dedicates appropriate financial resources.  

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Lithuania 

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Lithuania’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 2030 
ambition level 

Binding target for 
greenhouse gas 
(GHG) emissions 
compared to 2005 
under the Effort 
Sharing Regulation 
(ESR) (%)  

Binding target for 
net GHG removals 
under the 
Regulation on Land 
Use, Land Use 
Change and 
Forestry 
(LULUCF) 

National 
target/contribution 
for renewable 
energy: 

Share of energy 
from renewable 
sources in gross 
final consumption 
of energy (%) 

National 
contribution for 
energy efficiency: 

2022: +6.2%  
2023: +3.8%137 

-21% 

NECP: -21.3% 

2022: Reported 
net removals of   
- 6 Mt CO2 eq.  

 -0.66 Mt CO2 
eq.  
(additional 
removal 
target) 

Lithuania is expected to 
meet its target based on 
the latest projections: 
overachievement by - 0.31 
Mt CO2 eq 

26.8% 
(SHARES) 
30% 
 (target) 

2023: 32% 

55% 

Lithuania’s contribution 
of 55% is significantly 
above the 49% required 
pursuant to the formula 
of Annex II of the 
Governance 
Regulation138 

Lithuania’s primary 
energy consumption 
contribution is 5.4 Mtoe. 
EED recast Annex I 
formula results: 5.2 Mtoe 
(2020 EU Reference 
Scenario) and 5.4 Mtoe 
(Updated Reference 
Scenario). 

Primary energy 
consumption  

6.5 Mtoe 

2023: 6.34 Mtoe 

5.4 Mtoe 

137 
The  ESR emissions  in 2022 are based on  2024  final  GHG inventory  reports, and 2023 emissions are 
based on 2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as 
set out in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions 
for 2021-2025 will only be established in 2027 after a comprehensive review. 
138 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’). 

131 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
Final energy 
consumption 

4.3 Mtoe 

2023: 5.32 Mtoe 

4.4 Mtoe 

Level of electricity 
interconnectivity 
(%)139 

77.0% 

2024:41.0% 

15% 

Source: Eurostat; Lithuania’s final updated national energy and climate plan 

Lithuania’s final energy 
consumption 
contribution of 4.4 Mtoe 
is not in line with the 
national contribution of 
4.25 Mtoe submitted by 
the Commission. 

Lithuania surpasses the 
EU-wide 
interconnectivity target 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In  December  2023,  the  Commission  published  a  thorough  assessment  of  Lithuania’s  draft 
updated  NECP  and  provided  recommendations 140 for  the  preparation  of  the  final  updated 
NECP. Lithuania submitted its final updated NECP on 7 October 2024, over three months after 
the deadline of 30 June 2024.141 

2.1  DECARBONISATION 

Lithuania  expects  to  decrease  total  GHG  emissions  (excluding  LULUCF  and  excluding 
international aviation) by 44.6% in 2030 compared to 1990 and has committed to reach climate 
neutrality by 2050.  

2.1.1  Effort Sharing Regulation 
Lithuania has addressed recommendation 1. The final NECP provides sufficient details on 
how Lithuania will meet its ESR target of -21% by 2030 compared to 2005. The plan provides 
projections showing that the existing and planned policies and measures will lead to a decrease 
of 21.3% in 2030 compared to 2005, overachieving the ESR target by 0.3 percentage points. 
In 2023, GHG emissions from ESR sectors represented 74% of the total (expected to be 71% 
in 2030)142, with transport projected to represent the largest share.  

The  final  plan  complemented  the  information  on  the  policies  and  measures  provided  in  the 
draft but is still unclear on their scope, timeline and GHG impacts. The plan focuses on all ESR 
sectors. On transport, Lithuania expects an average annual reduction of approximately 5.4% 
between  2022  and  2030,  a  substantial  acceleration  compared  to  the  observed  increase  in 
transport emissions of 2.4% per year between 2015 and 2022143.  Lithuania set a national target 
to reduce transport emissions but according to their projections they will miss it by 4 percentage 
points. This indicates the need to closely monitor and scale up measures in the sector, such as 

139  Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2024). The 2030 level 

represents the general interconnectivity target of 15%.  

140 SWD(2023) 918 final, and Commission Recommendation of 18 December 2023, C/2023/9608. 
141 Article 14(2) of Governance Regulation. 
142 The  2023  emissions  are  based  on  2024  approximated  inventory  reports  and  2030  is  based  on  reporting  of 

greenhouse gas projections (Article 18 of the Governance Regulation). 

143 Compound annual growth rate 

132 

 
 
 
 
 
 
 
promoting the development of alternative fuels infrastructure and of intermodal transport, and 
the deployment of electric vehicles.  

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings, road transport and additional sectors (ETS2). The scenario projections account for 
the effect of ETS2 and its impact in achieving the ESR target.  

On  agriculture,  the  plan  provides  sufficient  detail  in  terms  of  funding  and  impacts  of 
agricultural measures.  

2.1.2  LULUCF 
Lithuania has addressed recommendation 3. The LULUCF sector in Lithuania generates net 
removals,  absorbing  roughly  34%  of  the  total  GHG  emissions  in  2022.  According  to  2022 
figures, Lithuania has slightly worsened its performance by 0.33 MtCO2eq in comparison to 
its yearly average in the 2016-2018 reference period. According to the LULUCF Regulation, 
Lithuania has to enhance its net removals by -0.66 MtCO2eq in 2030 compared to the reference 
period. In its 2030 projections Lithuania overachieves its LULUCF target by -0.31 Mt CO2eq 
in 2030. 

The creation of a strategic Lithuanian Agriculture and Rural Development Plan for 2023-2027 
played a key role in achieving this target. Lithuania expects to meet its national 2030 mitigation 
goals  through  a  continuous  increase  in  carbon  absorption  in  sustainable  agriculture  and 
forestry, wood use in construction, as well as natural habitat and peatland restoration. 

2.1.3  Carbon Capture and Storage 
Lithuania  has  addressed  recommendation  2.  The  plan  provides  a  strategy  on  CCUS 
including an assessment of the amount of CO2 emissions that could be captured annually by 
2030, broken down by source for fossil fuel and biogenic CO2 emissions. Overall, Lithuania 
plans to capture 0.2 million tonnes of CO2 emissions per year by 2030. The plan also provides 
details  on  how  the  captured  CO2  will  be  transported,  primarily  via  gas  carriers,  rail  and 
pipelines, with the possibility to construct a CO2 export terminal. The plan does not identify 
the overall CO2 storage capacity and injections volumes available by 2030.  

2.1.4  Adaptation 
Lithuania  has  partially  addressed  recommendation  4.  The  plan  refers  to  the  national 
adaptation  plan  for  2024-2030,  acknowledging  the  importance  of  integrating  adaptation 
planning. It partially embeds adaptation policies and measures in the relevant Energy Union 
dimensions.     

The  plan  contains  a  partial  analysis  of  climate  vulnerabilities,  and  identifies  several 
significant risks related to flooding, forest fires, droughts, and fluctuations in wind and solar 
energy. However, except for the risk related to flooding, it is short of a quantifiable assessment 
of  impacts.  The  plan  partially  outlines  the  links to  specific  Energy  Union  objectives  and 
policies that adaptation policies and measures are meant to support. It acknowledges seasonal 
shifts and flooding risks, which are essential to consider for climate-resilient infrastructure. It 
also refers to preservation of water resources and envisages measures in agriculture to reduce 
the  impacts  of  droughts.  However,  the  impacts  and  benefits  of  adaptation  policies  on  other 
Energy Union objectives have generally not been quantified.    

133 

 
 
 
 
 
The  plan  sets  out  some  additional  adaptation  policies  and  measures  to  support  the 
achievement of national objectives, targets and contributions under the Energy Union. The plan 
discusses  anticipated  changes  in  energy  demand  for  heating  and  cooling  and  acknowledges 
risks such as drought and floods, which are critical for safeguarding energy infrastructure and 
managing evolving electricity needs.  Although adaptation measures for residential cooling and 
heating are mentioned, they are explained in insufficient detail to assess their scope, timing and 
likely  impact. 
  Furthermore,  the  plan  does  not  extensively  address  the  financing, 
implementation, or scalability of adaptation measures, nor does it specify how policies will be 
monitored or adjusted over time. 

2.1.5  Fossil Fuels 
Lithuania has partially addressed recommendation 17. The plan identifies thirteen energy 
subsidies that will be phased out by 2026, the majority of which involve fossil fuels. However, 
the plan does not clarify whether these are all the remaining fossil fuel subsidies and states that 
some fossil fuel subsidies will remain as considered essential for the population, while some 
will be reduced but not phased out.  

2.2  RENEWABLES  

Lithuania  has  partially  addressed  recommendation  5.  Lithuania  does  not  provide 
information  on  the  deployment  of  renewable  energy  towards  2040.  Lithuania  has  included 
projections  policy  measures  for  an  increased  use  of  renewables  (as  well  as  green  hydrogen 
needs) in the industry, and buildings with their estimated effects on GHG emissions reduction. 
However, the final plan does not commit on specific targets for these sectors nor provide an 
indicative target for deployment of innovative renewable energy technologies by 2030.  

Lithuania has partially addressed recommendation 6. The final NECPs provides detailed 
and  quantified  information  about  the  policies  and  measures  it  envisages  for  achieving  its 
targets.  However,  there  is  no  information  about  renewables  acceleration  areas,  neither  on 
measures enabling integration of the electricity and heating and cooling networks, although the 
National Strategy for Energy Independence acknowledges this as a goal among future R&D&I 
priorities. The plan includes information on the design of the supply obligation in transport. 

Lithuania  has partially  addressed  recommendation 7. Lithuania  included sub-targets  for 
advanced  biofuels  and  renewable  fuels  of  non-biological  origin  (RFNBOs),  in  transport  by 
2030 and measures to develop sustainable production of biomethane.  

Lithuania has not addressed recommendation 8 as the plan lacks information on timelines 
and  procedural  steps  leading  to  the  transposition  of  the  provisions  of  the  Directive  (EU) 
2018/2001 (the ‘revised RED II’)144. 

2.3  ENERGY EFFICIENCY DIMENSION 

Lithuania  has  addressed  recommendation  9.  Lithuania  set  out  complete  policies  and 
measures  to  achieve  the  national  contributions  on  energy  efficiency,  such  as  higher  excise 

144 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  

134 

 
 
 
 
 
 
duties  and  taxes  on  fuel  consumption,  replacing  boilers  with  more  efficient  technologies, 
renovating  of  multi-apartment  buildings,  and  giving  VAT  relief  for  industrial  customers. 
Lithuania also quantified expected energy savings and the contribution for each of the reported 
energy efficiency measures.  

Lithuania established a National Energy Efficiency Fund and provided sufficient information 
on the role of the fund, as defined in Article 30 of Directive (EU) 2023/1791 (‘EED recast’)145  
in helping deliver the energy efficiency national contributions to the EU target, by including 
the use of financial instruments within the fund. 

Lithuania  has  not  addressed  recommendation  10.  Lithuania  did  not  increase  ambition 
regarding buildings energy consumption and GHG emissions compared to its draft update and 
its 2020 long-term renovation strategy. Lithuania’s goal is still to achieve net zero emissions 
in the building sector by 2040. The renovation measures are to be implemented mainly through 
financial support to the renovation of multi-apartment and single-family buildings, support to 
replacing  fossil-fuel  boilers,  and  support  to  complex  urban  renovation.  Lithuania  ensured 
consistency between the household final energy consumption and energy savings estimates for 
buildings. 

2.4  ENERGY SECURITY DIMENSION 

Lithuania  has  partially  addressed  recommendation  11.  The  final  updated  plan  does  not 
further  explain  how  Lithuania  intends  to  further  encourage  gas  demand  reduction  towards 
2030. However, the plan provides a projection for the evolution of natural gas consumption, 
which is expected to decrease from 950 ktoe in 2020, to 567 ktoe in 2030, and 539 ktoe in 
2040. 

Energy storage is mentioned in different parts of the plan, establishing targets for up to 2030. 
At  transmission  level,  the  Lithuanian  TSO  estimates  that  the  frequency  restoration  reserve 
(FRR) needs will increase from 700 MW in 2024 up to 1238 MW in 2030 with a gap of at least 
300 MW in 2027, which can be covered with a range between 300 and 600 MW of additional 
storage depending on its capacity. Storage is also mentioned as one of the key priority areas in 
research and development. 

The final plan did not update the oil section and therefore does not further assess the adequacy 
of the oil infrastructure (refinery, oil stocks) with the expected decline in oil demand and the 
move toward lower-carbon alternatives. 

2.5  INTERNAL ENERGY MARKET DIMENSION 

Lithuania  has  addressed  recommendation  12.  The  plan  outlines  measures  to  enhance 
flexibility  services, 
including  regulations  for  electricity  sharing,  flexibility  market 
participation, and compressed air storage development.  It also includes measures to enhance 
consumer empowerment as well as demand response and flexibility across the energy system. 
However,  the  plan  does  not  provide  sufficient  measures  facilitating  system  integration  of 
renewable electricity in line with article 20a of the revised RED II.  

145 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 

135 

 
 
 
 
 
 
 
Lithuania’s plan sets forth policies to achieve market integration by 2030, enhancing market 
liquidity, local generation, security of supply, competitiveness, and mitigate the impact of the 
energy transition on citizens and businesses.  

Lithuania has partially addressed recommendation 13. The updated NECP presents some 
energy  poverty  indicators.  The  plan  includes  a  more  ambitious  target  on  energy  poverty  as 
included  in  the  National  Progress  Plan  for  2030,  on  the  share  of  households  that  spend  a 
significant  share  of  their  income  on  energy  expenditure.  However,  the  plan  does  no  longer 
include the target on the share of families who are unable to keep their home adequately warm. 
Whereas the draft plan mentioned a target of 17% by 2030, the final plan no longer includes a 
target and projects that it will be 17.4% by 2040.  Lithuania commits to complete the framework 
of statistical indicators and set of measures for identifying, analysing, and eradicating energy 
poverty by 2030. The final NECP, however, contains commitment to include energy poverty 
definition into the national law by transposing the EED recast still in 2024.  

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Lithuania  has  partially  addressed  recommendation  14.  The  plan  includes  national 
objectives  in  research,  innovation,  and  competitiveness  to  deploy  clean  technologies, 
establishing a pathway to 2030, with a clear objective to support the decarbonisation of industry 
and the transition of businesses towards a net zero economy. Significant policies and measures 
include the 2024 revision of Lithuania’s National Energy Independence Strategy, the upward 
revision of the Smart  Specialisation Strategy’s budget  (EUR 747M), the  establishment of  a 
Centre for the Development of Energy Technology (2024-2030) and a significant increase in 
the budget for planned measures in research, innovation and competitiveness.  

The plan puts forward policies and measures to promote the development of net-zero projects, 
including for the energy intensive industries. It does not describe a predictable and simplified 
regulatory framework for permitting procedures for manufacturing or how access to national 
funding  will  be  simplified.  The  plan  presents  relevant  policies  and  measures  for  the 
digitalisation of the energy system (e.g.  implement research on the digitalisation of energy to 
boost the digitalisation of the energy sector); and for the development of clean energy-related 
skills (e.g. under the Smart Specialisation concept), while it includes less details on to open 
trade for resilient and sustainable supply chains of key net-zero components and equipment. 

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Lithuania  partially  addressed  recommendation  15.  The  plan  provides  an  estimate  of  the 
investment needs of 17.64 billion EUR to implement existing policy measures, and 13.5 billion 
EUR to implement planned policy measures, covering all sectors. More than half of them are 
public investments, mainly financed with EU funds. The assessment is based on a top-down 
model,  but  the  plan  does  not  provide  sufficient  information  on  the  methodology  used.  The 
information provided is also insufficient to assess a potential financing gap, or how this would 
be filled. The plan provides different funding sources but does not present a strategy to attract 
private investment.  

Lithuania provides a robust assessment of the macroeconomic impact, mainly focusing on 
sectoral GDP, but also covering air pollution, household disposable income, and employment. 

136 

 
 
 
 
 
However, the channels through which the planned policy framework will affect the economy, 
and the financing of measures could be explained in more detail. 

2.8  JUST TRANSITION 

Lithuania  has  partially  addressed  recommendation  18.  The  final  plan  includes  an 
assessment of the impact on macroeconomic indicators, which improves on the analysis of the 
social,  employment  and  skills  impacts  of  the  energy  and  climate  transition  but  doesn’t 
sufficiently  address  the  impact  on  the  most  vulnerable  households.  The  plan  discusses  the 
current labour market policies in place to increase employment opportunities for jobseekers, 
including measures focused on the achievement of the green transition and circular economy, 
as well as some upskilling measures. The plan explains how an interinstitutional working group 
was  established  in  June  2024  to  begin  preparations  for  the  Social  Climate  Plan  (SCP)  and 
highlighted how a technical assistance project has been initiated to identify vulnerable social 
groups, assess the socio-economic impact of ETS2, identify possible measures  for the most 
vulnerable households and micro-enterprises that could be included in the SCP. However, the 
government’s assessment on the estimated impact of ETS2 and the identification of vulnerable 
groups is not yet available, and therefore this information has not been provided in the final 
NECP. The plan also does not explain how the policy framework identified in the NECP will 
contribute to the preparation of Lithuania’s Social Climate Plan nor how the consistency of the 
two plans will be ensured. 

2.9  PUBLIC CONSULTATION 

Lithuania was not given a Commission recommendation on the public consultation process.   

2.10 REGIONAL COOPERATION 

Lithuania has partially addressed recommendation 19. Lithuania continues to build on a 
strong existing cooperation framework between the Baltic countries, Poland and Finland and 
is  actively  engaging  in  the  work  of  the  BEMIP  High-Level  group,  the  Baltic  Council  of 
Ministers,  and  the  Nordic  Council  of  Ministers. The  importance  of  well  interconnected  gas 
network is highlighted as one of the main instruments to ensure energy security in the Baltic 
region along with the upcoming synchronisation of the Baltic states’ electricity systems with 
the  Continental  Europe  in  February  2025.  The  plan  also  anticipates  the  need  of  regional 
cooperation in planning an interconnected market for transportation of CO2 and Hydrogen. 

Lithuania  did  not  provide  additional  information  on  concrete  plans  to  sign  the  bilateral 
solidarity arrangement for the security of gas supply with Poland.  

2.11 ANALYTICAL BASIS 

The plan includes an improved description of the analytical framework compared to the draft 
NECP. The methodology is based on a number of sectoral analytical tools covering energy, 
transport, waste, LULUCF, industry etc. In addition to the projections of the energy system 
and  greenhouse  gas  emissions  that  those  sectoral  tools  provide,  the  plan  also  includes  an 
assessment of macroeconomic impacts.   

137 

 
 
 
 
 
2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

Lithuania has partially addressed recommendation 16. The final NECP covers partly the 
main reforms and investments of the Recovery and Resilience Plan (RRP) that contribute to 
implementing the objectives, targets and contributions of the Energy Union. However, most of 
the investments and reforms addressed have not been recognized as part of the RRP, such as 
the investments to promote sustainable inland navigation. 

3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

The Commission encourages Lithuania to ensure a timely and complete implementation of the 
measures needed to achieve its national climate and energy targets. Lithuania is invited to pay 
particular attention to the following main elements:    

•  On  ESR,  closely  monitor  the  impacts  of  the  policies  included  in  the  plan  on  emission 
reductions,  particularly  for  the  transport  sector  (including  EV  deployment,  alternative 
infrastructure deployment and promoting intramodal transport).  

•  On  adaptation,  ensure  that  the  risk  assessment  adopts  a  more  quantitative  approach, 
specifying  anticipated  impacts  and  establishing  clear,  measurable  long-term  targets. 
Consider different climate scenarios. The risk assessment should describe in greater detail 
the  implementation,  financing,  scaling,  and  timing  of  adaptation  measures  to  ensure 
effective mitigation of climate risks.    
Implement the commitment to phase out the fossil fuels subsidies identified in the NECP 
by 2026. Clearly identify remaining fossil fuel subsidies and provide a detailed timeline for 
their gradual phase-out. 

• 

•  On  renewable  energy,  develop  a  more  comprehensive  plan  for  increasing  the  use  of 
renewables in industry and heating and cooling sectors, and identify innovative renewable 
energy  technologies  in  view  of  achieving  the  indicative  target  of  5%  by  2030.  Identify 
renewables acceleration areas, which will be subject to the new permitting procedures. 
In the context of promoting energy system integration, develop policy measures that can 
help realise the reported potential of demand response and electricity system flexibility. 
•  On energy efficiency, put in  place measures to  achieve the higher ambition  for  energy 
efficiency  by  2030.  Further  promote  energy  efficiency  in  industry,  including  through 
stronger requirements for energy audits and energy management systems.  

•  On buildings, ramp up the pace and depth of renovation in building stock including both 
residential and non-residential buildings and speed up the roll-out of the national financing 
schemes by increasing technical assistance and focusing on one-stop shops to achieve the 
objectives set in the Long Term Renovation Strategy (LTRS). 

•  Develop a more comprehensive just transition strategy, that address vulnerable households and 

present upskilling/reskilling strategies. Allocate sufficient financial resources. 

138 

 
 
 
 
 
 
Luxembourg 

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Luxembourg’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

2022: -30.2% 
2023: -31.7%146 

-50% 

NECP: -55.6% 

2022: Reported 
net removals of 
-0.65 Mt CO2 
eq. in 2022,  

– 0.03 Mt  
CO2 eq. 
(additional 
removal 
target) 

11.7% 
(SHARES) 
11% 
(target) 

2023: 14.4% 

37% 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for net 
GHG removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 
Share  of  energy 
from 
renewable sources in gross 
final 
of 
energy (%) 

consumption 

National contribution for 
energy efficiency: 

Primary 
consumption  

energy 

4.5 Mtoe 

2023: 3.7 Mtoe 

3.28 Mtoe 

Final energy consumption 

4.2 Mtoe 

2023: 3.5 Mtoe 

3.18 Mtoe 

146  The ESR emissions in 2022 are based on 2024 final GHG inventory reports, and 2023 emissions are based on 
2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as set out 
in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions for 2021-
2025 will only be established in 2027 after a comprehensive review. 
147 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’). 

139 

LUis expected to 
meet its target 
based on the latest 
projections 

Luxembourg´s 
contribution of 
37% is in line 
with the level 
required pursuant 
to the formula set 
out in Annex II of 
the Governance 
Regulation147. 

Luxembourg´s 
primary energy 
consumption 
contribution is 
3.28 Mtoe. EED 
recast Annex I 
formula results: 
2.82 Mtoe (2020 
EU Reference 
Scenario) and 2.8 
Mtoe (Updated 
Reference 
Scenario) 

Luxembourg´s 
final energy 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Level of electricity 
interconnectivity (%)148  

55.2% 

163.8% 

15% 

consumption 
contribution is 
3.18 Mtoe. 
Corrected 
contribution 
notified by the 
Commission in 
March 2024: 2.8 
Mtoe. 

Luxembourg´s 
surpasses the EU-
wide 
interconnectivity 
target. 

Source: Eurostat; Luxembourg’s final updated national energy and climate plan 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In December 2023, the Commission published a thorough assessment of Luxembourg’s draft 
updated  NECP  and  provided  recommendations 149 for  the  preparation  of  the  final  updated 
NECP.  Luxembourg  submitted  its  final  updated  NECP  on  24  July  2024,  a  month  after  the 
deadline of 30 June 2024.150 

2.1  DECARBONISATION 

Luxembourg  expects  to  decrease  total  GHG  emissions  (including  LULUCF  and  excluding 
international aviation) by 59% in 2030 and by 87% in 2040 compared to 1990. Luxembourg 
committed to bring net GHG emissions to zero by 2050.   

2.1.1  Effort Sharing Regulation 
Luxembourg  has  addressed  recommendation  1.  The  final  NECP  provides  sufficient 
information on how Luxembourg will meet its ESR target of -50% by 2030 compared to 2005.  

The plan provides updated projections showing that with the existing and planned policies and 
measures,  Luxembourg  will  reduce  ESR  emissions  by  55.6%  by  2030  compared  to  2005, 
overachieving  their  ESR  target  by  5.6  percentage  points.  The  ‘with  additional  measures’ 
(WAM) projected value in  2030 is roughly  33% lower than the  projections under the ‘with 
existing measures’ (WEM) scenario, hinting that implementing the plan and complementing it 
with  additional measures to  reach the target  will  require  a significant  effort. In 2023,  GHG 
emissions from ESR sectors represented 89% of the total in Luxembourg (expected to be 84% 
in 2030151), with transport projected to represent the largest share.  

The  final  plan  complemented  the  information  on  the  policies  and  measures  provided  in  the 
draft. For transport, the WAM projections indicate an annual average emissions decrease of 

148  Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2024). The 2030 level 
represents the general interconnectivity target of 15%. 
149 SWD(2023) 919 final, and Commission Recommendation of 18 December 2023, C/2023/9609. 
150 Article 14(2) of Governance Regulation. 
151 Total  GHG  emissions  including  LULUCF.  Source:  Commission  calculations  based  on  latest  data  from  the 
European Environmental Agency (EEA) 

140 

 
 
 
 
 
 
 
6.5% per year from 2022 to 2030, in contrast to a 4.1% decline between 2015 and 2022152.  The 
plan provides details on several measures to  reduce transport emissions, including the 2035 
National Mobility Plan; the rollout of electric buses; charging infrastructure and incentives for 
electric cars (including a leasing scheme for disadvantaged households); and the increase of 
the CO2 tax.  

On  agriculture,  the  plan  provides  sufficient  detail  in  terms  of  funding  and  impacts  of 
agricultural measures. The WAM projections show a considerable reduction of 21% between 
2022 (latest reported data) and 2030.  

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings,  road  transport  and  additional  sectors  (ETS2).  The  scenario  projections  do  not 
account  for  the  effect  of  ETS2  and  do  not  quantify  its  impact  in  achieving  the  ESR  target. 
However,  the  plan  refers  to  the  current  CO2  taxation  in  Luxembourg  and  the  related  social 
measures. 

2.1.2  LULUCF 
Luxembourg  has  addressed  recommendation  3.  The  LULUCF  sector  in  Luxembourg 
generates net removals, absorbing roughly 8% of the total GHG emissions in 2022. According 
to 2022 figures, Luxembourg has improved its performance by 0.29 MtCO2eq compared to its 
yearly  average  in  the  2016-2018  reference  period.  According  to  the  LULUCF  Regulation, 
Luxembourg has to enhance its net removals by -0.03MtCO2 eq in 2030 as compared to the 
reference period. In its 2030 projections Luxembourg overachieves its LULUCF target by  -
0.04 Mt CO2eq in 2030. The final plan includes information on progress in ensuring higher 
tier levels and geographically explicit datasets needed to ensure the robustness of net removal 
estimates. 

2.1.3  Carbon Capture and Storage 
Luxembourg  has  not  addressed  recommendation  2.  The  plan  indicates  that  by  2030  the 
amount of CO2 captured will be negligible, but a significant amount may occur after 2030. The 
Government plans to assess the potential of CCUS technologies in Luxembourg, especially for 
process emissions in industries as cement. They will work on transport infrastructure where 
EU cooperation is essential. 

2.1.4  Adaptation 
Luxembourg did not receive a recommendation on adaptation.   

2.1.5  Fossil Fuels 
Luxembourg has partially addressed recommendation 17. The plan mentions that by the 
end  of  2024,  all  crisis-related  fossil  fuel  subsidies  will  expire.  It  also  mentions  the  general 
commitment to phase out remaining fossil fuel subsidies, referring to the COP28 international 
coalition committed to phase out fossil fuel subsidies. However, the phase-out of fossil fuel 
subsidies is only briefly mentioned in the context of the increase of excise duties for transport, 
without a description of the subsidies nor a roadmap and timeline for phasing them out. 

152 Compound annual growth rate 

141 

 
 
 
 
 
 
2.2  RENEWABLES  

Luxembourg has partially addressed recommendation 4. Estimated trajectories based on 
their  updated  NECP  target  scenario  (i.e.  WAM  scenario  reaching  a  37%  RES-share)  are 
provided, including an outlook for 2040. Overall, the final plan does not confirm whether the 
included trajectories for different sectors constitute the specific targets that contribute to the 
sectoral  targets  of  Directive  (EU)  2018/2001  (the  ‘revised  RED  II’) 153.  More  specifically 
Luxembourg  has  not  included  an  indicative  target  for  innovative  renewable  energy 
technologies  by  2030,  indicative  sub-targets  in  buildings  or  in  industry,  a  specific  target  to 
contribute to the binding sub-targets for RFNBOs in industry, indicative target in heating and 
cooling to achieve the top-ups of Annex IA or an indicative target in district heating and cooling 
for  2021-2030.  Luxembourg  has  included  trajectories  for  advanced  biofuels  and  renewable 
fuels of non-biological origin (RFNBOs), in transport by 2030 as well as information about the 
design of the supply obligation including limits for certain types of biofuels and the inclusion 
of a credit mechanism. 

Luxembourg has addressed recommendation 5. The final updated NECP provides further 
detail  on  measures  related  to  renewable  deployment,  renewable  hydrogen,  international 
cooperation  and  heating  and  cooling154.  Solar  and  wind  are  mentioned  as  technologies  for 
which Luxembourg plans to designate renewable acceleration areas. The final NECP mentions 
that permitting procedures should be accelerated and simplified, in line with the revised RED 
II.  Further  details  on  how  Luxembourg  plans  to  achieve  this  are  however  not  given.  The 
acceleration  of  renewables  through  the  promotion  of  self-consumption,  power  purchase 
agreements and energy communities are covered by multiple measures in the final NECP.  

Luxembourg  has  partially  addressed  recommendation  6.  The  final  NECP  provides 
projections  of  energy  production  from  solid  biomass  for  2021-2030.  It  also  foresees  an 
assessment of the domestic supply of forest biomass for energy purpose to be carried out in 
2024. An assessment of  the compatibility  of the  projected use of forest  biomass  for energy 
production  with  Luxembourg’s  obligations  under  the  revised  LULUCF  Regulation, 
particularly  for  2026-2030,  together  with  national  measures  and  policies  to  ensure  such 
compatibility  is  missing.  Finally,  Luxembourg  includes  further  measures  to  promote  the 
sustainable production of biogas/biomethane and digestate. 

Luxembourg has partially addressed recommendation 7 as the final NECP lacks details on 
the procedural steps and timelines for most policies and measures. 

2.3  ENERGY EFFICIENCY DIMENSION 

Luxembourg  has  partially  addressed  recommendation  8.  Luxembourg  includes  an 
indicative national contribution of 3.2 Mtoe to the Union’s binding final energy consumption 

153 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  
154 Further detail compared to the draft NECP is given for measures 205, 218, 219, 221, 222 and 223. An update 
on the description is given for measures 209, 216 and 217. 

142 

 
 
 
 
 
 
target for 2030 for final energy consumption. This contribution is not in line155 with Article 
4 of Directive (EU) 2023/1791 (‘EED recast’)156, nor equal to the corrected indicative national 
contribution that the Commission submitted to Luxembourg in March 2024. There is still a gap 
of 17.1% compared to the target calculated with respect to the indicative results of the 2020 
reference scenario and a gap of 16.2% compared to the target calculated with respect to the 
indicative results of the updated 2020 reference scenario. Luxembourg includes an indicative 
national  contribution  of  3.3  Mtoe  to  the  Union’s  indicative  primary  energy  consumption 
target for 2030157 but the contribution is not in line with Article 4. There is still a gap of 16.2% 
compared to the target calculated with respect to the indicative results of the 2020 reference 
scenario, and a gap of 15.3% compared to the target calculated with respect to the indicative 
results of the updated reference scenario. 

Luxembourg sets  a yearly energy consumption reduction target  of 1.26 ktoe158 to  all public 
bodies, which is also disaggregated by sector. Luxembourg reports the total floor area of 1,832 
m2 of heated and cooled buildings owned by public bodies to be renovated yearly in line with 
Article 6 of EED Recast, and it specified that it opted for the default approach. Luxembourg 
set  out  policies  and  measures  to  achieve  the  reduction  of  energy  consumption  from  public 
bodies, and the renovation of public buildings. 

Luxembourg  has  partially  addressed  recommendation  9.    Luxembourg  set  out  adequate 
measures to promote energy audits and energy management systems but does not quantify the 
expected  energy  savings  nor  the  contribution  for  each  of  the  reported  energy  efficiency 
measures.  Regarding  financing,  Luxembourg  specified  robust  energy  efficiency  financing 
programmes and support schemes, including financial instruments and public guarantees, able 
to  mobilise private investments and additional co-financing.  Luxembourg specified existing 
policy measures to promote the uptake of energy efficiency lending products and innovative 
financing schemes such as Energy Performance Contractors, ESCOs and third-party financing. 
Luxembourg  established  a  National  Energy  Efficiency  Fund  and  provided  sufficient 
information on the fund, in helping deliver the energy efficiency national contributions to the 
EU target, by including the use of financial instruments within the Fund.   

Luxembourg has partially addressed recommendation 10. The ambition of the 2030 and 
2040  intermediate  milestones  for  buildings  is  increased  in  comparison  to  the  Long-Term 
Renovation Strategy 2020, but there is no quantitative milestone for 2050. The building sector 
is targeted throughout several sections of the plan, through financing schemes and regulatory 
standards.  The  plan  does  not  include  milestones  in  terms  of  renovation  or  energy  savings 
related to non-residential buildings.  

2.4  ENERGY SECURITY DIMENSION 

Luxembourg has partially addressed recommendation 11. The final updated plan provides 
additional details on Luxembourg’s plans to further encourage gas demand reduction, notably 
with a reference to a new national energy saving campaign. The plan does not, however, include 

155 Luxembourg explained that it cannot commit to the targets in line with the EED. WAM scenario projections 
have been used instead. 
156 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 
157 Number is only given in a table and not reported explicitly as target. 
158 Figures under elaboration. 

143 

 
 
 
 
 
 
any  other  additional  policy  or  measures  to  strengthen  the  national  security  of  gas  supply 
compared to the draft updated plan. It is however noted that the final plan contains a forecast 
for the evolution of natural gas demand, which should decrease from 157 GWh in 2022 to 31 
GWh in 2030 and 0 in 2040 (WAM scenario). 

The plan refers to the storage of renewable energy as a priority technological objective but does 
not provide any new information compared to the initial draft. It also maintains that setting up 
network development plans would also help to facilitate the establishment of energy storage 
facilities, but without providing more details.  

The plan contains oil consumption forecasts until 2050. The plan does not assess the adequacy 
of the oil infrastructure with the expected oil demand decline and the move towards lower-
carbon alternatives, or the impact of the large proportion of stocks currently held abroad (86%) 
on security of supply. 

Luxembourg  highlights  that  it  is  preparing  for  the  effects  of  climate  change  and  its  future 
impact  on  energy  infrastructure  but  does  not  specify  policies  and  measures  to  integrate  the 
imperative of climate adaptation in the energy system. 

2.5  INTERNAL ENERGY MARKET DIMENSION 

Luxembourg has partially addressed recommendation 12. Luxembourg does not provide 
any new information on the objectives and targets for demand response or storage to improve 
the flexibility of the energy system. However, Luxembourg provides descriptions of measures 
to facilitate the integration of new technologies and to make the energy system more flexible. 
Luxembourg  presents  descriptions  of  measures  such  as  the  express  support  mechanism  for 
flexibility, the smart meter rollout, dynamic electricity price contracts, new tariff structure for 
network tariffs, an energy data platform, and a regulatory framework for aggregation. Even 
though the plan contains a good overview of measures promoting flexibility solutions in the 
context of facilitating energy system integration, it does not provide information on specific 
measures for facilitating system integration of renewable electricity in accordance with Article 
20a of the revised RED II. 

Luxembourg  has  partially  addressed  recommendation  13.  Luxembourg  describes  the 
calculation of the national energy poverty rate. However, it does not set a measurable reduction 
target as required by Governance Regulation. Luxembourg describes in detail the measures put 
in place to address energy poverty, which are set in social policy, as well as in energy policy. 
The structural measures put in place include access to renewable energy as well as measures 
aiming  to  increase  the  energy  efficiency  of  housing  occupied  by  the  energy  poor.  It  does 
however not explain how the use of energy efficiency measures under the Energy Efficiency 
Obligations  Scheme  to  alleviate  energy  poverty  is  foreseen  to  be  deployed  as  required  by 
Governance Regulation. 

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Luxembourg  has  addressed  recommendation  14.  The  plan  includes  national  targets  or 
measures  to  support  research,  innovation  and  to  deploy  clean  technologies,  establishing  a 
pathway  for  2030.  However,  it  does  not  include  clear  competitiveness  targets.  The  plan 

144 

 
 
 
 
 
 
provides  sufficient  details  on  research  and  innovation  dedicated  to  circular  economy  (in 
particular, the Circular Economy strategy 2023-2028).  

The  plan  describes  how  to  ensure  a  predictable  and  simplified  regulatory  framework  for 
permitting procedures for manufacturing and the needs to simplify access to national funding. 
The plan provides policies and measures for the digitalisation of the energy system, and for the 
development of clean energy-related skills. It also includes measures to facilitate open trade 
for resilient and sustainable supply chains of key net-zero components and equipment.  

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Luxembourg has partially addressed recommendation 15. The plan provides an updated 
estimate of the total additional investment needs for the period 2023-2040 of EUR 8.5 billion 
compared to the WEM baseline. As in the draft plan, it covers the buildings, transport, industry, 
and energy sectors.  One third of the investment needs are private investment, two thirds are 
public investments and subsidies. The assessment is based on a sound methodology, using both 
a bottom-up and a top-down economy-wide approach. It is not clear to which extent additional 
national  funding  needs  will  be  covered  by  the  planned  budget  and  if  there  is  a  potential 
financing gap. The plan does not specify reforms and measures to mobilise private investments, 
nor does it provide more details on the provision of state subsidies beyond what was already 
outlined in the draft plan. 

The  plan  provides  a  robust  macro-economic  assessment,  though  the  analysis  is  not 
disaggregated by sector. The methodology used for the assessment is clear. 

2.8  JUST TRANSITION 

Luxembourg  has  partially  addressed  recommendation  18.  The  plan  provides  some 
information on the impact of the transition to climate neutrality on employment but does not 
sufficiently address the impact on the most vulnerable groups. It lists some measures to support 
the just transition including (re)skilling and upskilling, and the financial support schemes in 
the framework of the Just Transition Fund and Just Transition Mechanism. Luxembourg plans 
to further assess the impacts on labour markets for the preparation of the Social Climate Plan. 

The plan misses  the analytical  basis for the preparation of the Social Climate Plan, such as 
estimates of the impact of ETS2, the links to the existing carbon tax, and the identification of 
vulnerable  groups.  Though  the  plan  indicates  that  Luxembourg’s  carbon  tax  revenues  are 
ringfenced to fund measures contributing to a just transition, it does not explain how they will 
be combined with the resources from the Social Climate Fund. The plan does not explain how 
the  policy  framework  identified  in  the  NECP  will  contribute  to  the  preparation  of 
Luxembourg’s Social Climate Plan or how the consistency of the two plans will be ensured, 
except for a reference to the existing CO2 taxation at national level. 

2.9  PUBLIC CONSULTATION 

Luxembourg has not addressed recommendation 19. While Luxembourg conducted a 30-
day public consultation for the draft updated NECP, it did not provide a summary of how the 
final plan integrated the views expressed during the consultation.   

145 

 
 
 
 
 
2.10 REGIONAL COOPERATION 

Luxembourg  has  partially  addressed  recommendation  20.  The  plan  includes  a  list  of 
initiatives  aiming  at  increasing  engagement  with  neighbouring  Member  States,  notably 
Belgium and Germany, and in particular a political agreement to sign a solidarity agreement 
with Belgium. However, the final plan does not mention any progress nor efforts to sign the 
bilateral solidarity arrangement for the security of gas supply with Germany. 

2.11 ANALYTICAL BASIS 

The plan provides a description of the analytical framework, with projections reaching 2050. 
It  provides  an  impact  assessment  along  the  dimensions  of  the  Energy  Union.  The 
methodologies used are described in detail. The policies and measures have been updated to 
reflect developments since July 2023. 

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

Luxembourg  has  addressed  recommendation  16.  The  plan  sufficiently  covers  the  main 
reforms  and  investments  of  the  Recovery  and  Resilience  Plan  (RRP)  that  contribute  to 
implementing the objectives, targets, and contributions of the Energy Union. The NECP covers 
all measures from the REPowerEU chapter. However, it does not specify that they are funded 
by the RRP. This is understandable considering that the REPowerEU chapter was only adopted 
after the submission of the final updated NECP. 

All investments under the green transition pilar are well reflected in the plan. 

3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

The Commission encourages Luxembourg to ensure a timely and complete implementation of 
the measures needed to achieve its national climate and energy targets. Luxembourg is invited 
to pay particular attention to the following main elements:  

•  On ESR, implement the additional measures outlined in the NECP as, though Luxembourg 
expects  to  achieve  its  target,  a  significant  part  of  the  emissions  reduction  is  driven  by 
measures that are not yet fully in place.  

•  On  adaptation,  consider  using  the  upcoming  update  of  the  national  climate  adaptation 
strategy  to  carry  out  a  comprehensive  vulnerability  assessment  of  the  network  and 
infrastructure, based on different climate scenarios. This would enable identifying potential 
weaknesses of the  energy system as  regards  climate  resilience  and develop  measures to 
address them.  
Identify fossil fuel  subsidies  and set  a roadmap  and specific measures for their gradual 
phase-out. 

• 

•  On  energy  efficiency,  put  in  place  measures  to  achieve  the  higher  ambition  for  energy 
efficiency by 2030. Set further measures to streamline the energy efficiency first principle 
across all relevant sectors to support the achievement of required energy savings.   

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•  On buildings, set policies, measures and financing to reduce energy consumption and GHG 
emissions in the building sector in view of decarbonising the building stock by 2050.  
•  Further promote the electrification of heating and roll out of heat pumps by addressing the 

unbalanced electricity-to-gas-price ratio.  

•  Adopt a more comprehensive just transition strategy that addresses the impact on 

vulnerable households and identify the available financial resources.  

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Hungary 

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Hungary’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

2022: -8.1% 
2023: -14.7%159 

-18.7% 

NECP:  
-25% 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for net 
GHG removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 
Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

13.85% 
(2020, 
SHARES) 
13% 
(target) 

National contribution for 
energy efficiency: 

2022: reported 
net removals of 
-6.8 MtCO2 eq. 
in 2022 

-0.93 Mt CO2 
eq. (additional 
removal 
target) 

2023: 17.1% 

30% 

Primary energy 
consumption  

26.6 Mtoe 

2023: 22.1 Mtoe 

24.1 Mtoe 

Expected to meet 
its target: a gap of 
0.12 Mt CO2 eq 
compared to the 
2030 target  

Hungary’s 
contribution of 
30% is 
significantly 
below the 
required 34% 
persuant to 
formula set out in 
Annex II of the 
Governance 
Regulation160 

HU primary 
energy 
consumption 
contribution is 
24.1 Mtoe. EED 
recast Annex I 
formula results: 
23.3 Mtoe (2020 
EU Reference 
Scenario) and 23.4 
Mtoe (Updated 
Reference 
Scenario) 

159  The ESR emissions in 2022 are based on 2024 final GHG inventory reports, and 2023 emissions are based 
on 2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as set 
out in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions for 
2021-2025 will only be established in 2027 after a comprehensive review. 
160 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’). 

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Final energy consumption 

18.2 Mtoe 

2023: 16.8 Mtoe 

17.7 Mtoe 

Level of electricity 
interconnectivity (%)161 

35.3% 

2024: 41.7% 

15% 

Source: Eurostat; Hungary’s final updated national energy and climate plan. 

HU final energy 
consumption 
contribution of 
17.7 Mtoe is not 
inline with the 
national 
contribution of 
16.2 Mtoe 
submitted by the 
Commission. 

HU has surpassed 
the EU-
wideconnectiviy 
target 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In  December  2023,  the  Commission  published  a  thorough  assessment  of  Hungary’s  draft 
updated  NECP  and  provided  recommendations 162 for  the  preparation  of  the  final  updated 
NECP. Hungary submitted its final updated NECP on 15 October 2024, over three months after 
the deadline of 30 June 2024.163 

2.1  DECARBONISATION 

Hungary  expects  to  decrease  total  GHG  emissions  (including  LULUCF  and  excluding 
international  aviation)  by  54%  in  2030  compared  to  1990.  The  NECP  builds  on  Hungary’s 
legally  binding  commitment  to  achieve  climate  neutrality  by  2050  but  does  not  provide 
projections of GHG emission reductions to net zero by 2050. 

2.1.1  Effort Sharing Regulation 
Hungary has addressed recommendation  1. The final NECP provides sufficient detail on 
how Hungary will meet its ESR target of 18.7% by 2030 compared to 2005.  

The plan provides updated projections that mark a slight improvement compared to the draft 
plan, showing that the existing and planned policies and measures will lead to a decrease of 
25% in 2030 compared to 2005, an overachievement of 6.3 percentage points compared to the 
national ESR target. In 2023, GHG emissions from ESR sectors represented 75% of the total 
in Hungary (expected to be 76% in 2030)164, with transport projected to represent the largest 
share. The ‘with additional measures’ (WAM) projected value in 2030 is approximatively 11% 
lower than the projections under the ‘with existing measures’ (WEM) scenario, hinting that 

161  Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2024). The 2020 figure 
also covers interconnectors with the neighbouring countries outside the EU. The 2030 level represents the general 
interconnectivity target of 15%.  
162 SWD(2023) 916 final, and Commission Recommendation of 18/12/2023, C/2023/9606. 
163 Article 14(2) of Governance Regulation. 
164 The  2023  emissions  are  based  on  2024  approximated  data  from  annual  reporting  of  final  greenhouse  gas 
inventory (Article 26 of the Governance Regulation). 

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implementing the plan and complementing it with additional measures to reach the target will 
require a significant effort. The plan provides projections showing that the existing and planned 
policies  and  measures  will  deliver  on  the  national  GHG  target  without  making  use  of 
flexibilities.  

The  final  plan  complemented  the  information  on  the  policies  and  measures  provided  in  the 
draft, including – albeit in a limited manner – on agriculture and non-CO2 emissions. The plan 
provides for a balanced sectoral coverage. For what concerns transport, the WAM projections 
describe a significant change of the expected trend in emissions, with the average percentage 
change going from +3.02% per year in the period 2015-2022 to -5.34% in the period 2022-
2030.165 

As  regards  industrial  energy  demand,  the  plan  outlines  efforts  to  reduce  energy  intensity. 
However, the implications of increased energy consumption from new manufacturing projects, 
notably in the battery industry, are not addressed in detail. 

The plan does not refer to the introduction of the emissions trading system for fuel combustion 
in  buildings, road transport and additional sectors (ETS2). Nonetheless,  the  WAM scenario 
accounts for the effect of ETS2, though not clearly quantifying its contribution to achieving 
the ESR target.  

2.1.2  LULUCF 
Hungary  has  partially  addressed  recommendation  3.  The  LULUCF  sector  in  Hungary 
generates net removals, absorbing roughly 11% of the total GHG emissions in 2022. According 
to  2022  figures,  Hungary  has  improved  its  performance  by  roughly  1.9  MtCO2eq  in 
comparison to its yearly average in the 2016-2018 reference period. According to the LULUCF 
Regulation, Hungary has to enhance its net removals by -0.93 Mt CO2eq in 2030 as compared 
to the reference period. Based on the projections provided, Hungary will have a gap of 0.12 
MtCO2eq in 2030.  

The plan does not provide sufficient information on how public funding (CAP, State aid) and 
private financing through carbon farming schemes are used to reach the LULUCF target. The 
final  plan  lacks  information  on  the  status  and  progress  in  ensuring  higher  tier  levels  and 
geographically explicit datasets needed to guarantee the robustness of net removal estimates. 

2.1.3  Carbon Capture and Storage 
Hungary  has  not  addressed  recommendation  2.  The  plan  does  not  include  a  detailed 
breakdown of the potential annual CO2 emissions that could be captured by 2030. It does not 
include information on the development of CO2 transport infrastructure or on the overall CO2 
storage capacity and injection volumes available by 2030.  

2.1.4  Adaptation 
Hungary  has  partially  addressed  recommendation  4.  The  plan  refers  to  the  National 
Adaptation Strategy (NAS) to respond to the recommendation, acknowledging the importance 
of integrating adaptation planning. It also partially embeds adaptation policies and measures in 
the relevant Energy Union dimensions.   

165 Compound annual growth rate. 

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The  plan  contains  a  partial  analysis  of  climate  vulnerabilities  and  risks.  It  includes  no 
reference  to  the  climate  vulnerabilities  and  risks  analysis  in  the  National  Adaptation  Plan. 
However, it recognizes the general vulnerability of the country to climate change but without 
going into details, except for impacts on forestry. The plan is short of quantifiable assessment 
of impacts. Among others, a recognition of vulnerability of nuclear power to the availability of 
cooling water is lacking, despite recent difficulties in cooling the Paks Nuclear Power Plant 
with river water during heatwaves.  

The plan partially outlines the links to the specific Energy Union objectives and policies 
that  adaptation  policies  and  measures  are  meant  to  support.  However,  it  only  mentions  the 
contribution of adaptation for forestry and energy security. The plan refers to the importance 
of adaptation research. The impacts and benefits of adaptation policies on other Energy Union 
objectives  have  generally  not  been  quantified.  The  impact  assessment  chapter  mentions  the 
need to take into account climate adaptation when carrying out building renovations, but this 
is not reflected in the chapter on policies and measures.    

The  plan  sets  out  some  additional  adaptation  policies  and  measures  to  support  the 
achievement of national objectives, targets and contributions under the Energy Union. While 
the inclusion of an adaptation category in the list of policies and measures is a positive step, 
the way these measures contribute to adaptation objectives and to the resilience of the energy 
system remains insufficiently detailed.  

2.1.5  Fossil Fuels 
Hungary has partially addressed recommendation 19. The plan mentions the phase-out of 
coal by 2029. The commitment to phase out the use of lignite in the three regions covered by 
Territorial Just Transition Plans (TJTPs) in Hungary is 2025. The plan does not sufficiently 
explain  the  alignment  between  the  NECP  and  TJTPs,  nor  the  timeline  for  the  updated  coal 
phase-out  commitments,  including  those  related  to  lignite  extraction  in  mines  (Visonta  and 
Bükkábrány).  

The plan includes a timeline to phase out heating-related fossil fuel subsidies for households 
and industry (e.g. stand-alone fossil fuel boilers) but not for phasing out other, direct or indirect 
types of fossil fuel subsidies166. 

2.2  RENEWABLES  

Hungary  has  partially  addressed  recommendation  5.  The  plan  includes  an  updated 
contribution based on the WAM scenario of renewable energy of 30% in gross final energy 
consumption by 2030. Even though this contribution is slightly higher than 29% included in 
the draft NECP, it remains significantly below the 34% as calculated in line with the formula 
in Annex II of Governance Regulation. The indicative trajectory for achieving the contribution 
is provided, with the specific reference points of 22% for 2025 and 25% for 2027 respectively, 
with the reference point for 2027 being slightly below the level (26%) calculated in line with 
the Governance Regulation.  

166 The Commission 2024 study and  Report on Energy subsidies in the EU identifies the existence of fossil fuel 
subsidies. 

151 

 
 
 
 
 
 
Hungary  has  partially  addressed  recommendation  6.  The  NECP  includes  additional 
information  about  renewables  deployment  over  the  2030-2040  period.  Hungary  does  not 
provide a specific target for renewable fuels of non-biological origin (RFNBOs) in industry but 
mentioned the significant needs for imports to achieve the binding sub-target of RFNBOs of 
Directive (EU) 2018/2001 (the ‘revised RED II’)167. 

The  plan  does  not  incorporate  a  specific  target  for  buildings,  but  the  projected  share  of 
renewable  energy,  with  a  breakdown  per  technology,  was  revised  upward,  with  a  stronger 
emphasis on heat pumps. The annual increase in the share of renewables in heating and cooling 
is above the binding target of the revised RED II but below the additional indicative top ups in 
line  with  Annex  IA.  Hungary  does  not  provide  information  on  a  target  for  deployment  of 
innovative renewable energy technologies by 2030.  

Hungary  has  partially  addressed  recommendation  7.  Hungary  provides  additional 
information on measures on phasing out fossil fuels in heating and cooling sector. However, 
the plan lacks information on how it will facilitate the uptake of power purchase agreements, 
promote renewable hydrogen uptake in industry and how it aims to ensure the imports. Even 
though the plan refers to the introduction of a new regulatory framework for permitting it does 
not  specify  the  nature  and  expected  impact  of  these  measures  and  does  not  indicate 
technologies for which Hungary aims to designate renewable acceleration areas.  

Hungary  has  addressed  recommendation  8.  The  plan  provides  additional  information  on 
projections on bioenergy demand and supply disaggregated per sector (heating and cooling, 
electricity, transport). It also provides the source and projected use of forest biomass used for 
energy and an assessment of the compatibility of the projected use of forest biomass for energy 
production with Hungary’s obligations under the revised LULUCF Regulation. Hungary also 
includes measures to promote the sustainable production of biomethane and biogas. 

Hungary has not addressed recommendation 9. The NECP does not include information on 
the  expected  timeline  and  procedural  steps  in  relation  to  adoption  of  policies  and  measures 
aimed at transposing and implementing the provisions of the revised RED II. 

2.3  ENERGY EFFICIENCY DIMENSION 

Hungary has not addressed recommendation 10. Hungary’s indicative national contribution 
of 17.7 Mtoe to the Union’s binding final energy consumption target for 2030 is not in line 
with the requirements of Article 4 of Directive (EU) 2023/1791 (‘EED recast’)168. There is a 
gap of 9.3% compared to the corrected indicative contribution that the Commission submitted 
to  Hungary.  Furthermore,  Hungary’s  indicative  national  contribution  of  24.1  Mtoe  to  the 
Union’s  indicative  primary  energy  consumption  target  for  2030  for  primary  energy 
consumption169 is not in line with Article 4. There is still a gap of 3.5% compared to the target 
calculated with respect to the indicative results of the 2020 reference scenario, and a gap of 

167 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  
168 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 
169 The target is marked as non-binding. 

152 

 
 
 
 
 
 
3.3% compared to the target calculated with respect to the indicative results of the updated 
2020 reference scenario. 

Hungary  includes  an  energy  consumption  reduction  target  of  0.081  Mtoe  by  2030  to  be 
achieved by all public bodies. Hungary does not report the total floor area of heated and/or 
cooled buildings owned by public bodies to be renovated yearly but reported the corresponding 
energy savings to be achieved170 but does not specify if it opted for the alternative or default 
approach171. Hungary sets out some policies and measures to reduce the energy consumption 
from public bodies, and to promote the renovation of public buildings. 

Hungary includes the amount of cumulative energy savings of 8.0 Mtoe172 to be achieved 
over  the  period  from  2021  to  2030,  which  is  not  in  line  with  Article  8  of  EED  Recast  nor 
include  an  explanation  on  how  the  annual  savings  rate  and  the  calculation  baseline  were 
established. 

Hungary  has  partially  addressed  recommendation  11.  Hungary  sets  out  policies  and 
measures to support the achievement the national contributions on energy efficiency, as well 
as the cumulative end-use energy savings, but it does not quantify each of the reported energy 
efficiency measures173 nor the savings from measures targeting energy poverty.  

Hungary specifies how the energy efficiency first principle will be implemented but it does 
not mention any measures to implement or monitor the implementation174. Hungary sets out 
adequate measures to promote energy audits and energy management systems, including an 
obligation for large companies to carry out an energy audit every four years or to operate an 
energy management system. 

Hungary has partially addressed recommendation 12. Hungary does not include updated 
milestones in comparison to the long-term renovation strategy (LTRS) submitted in 2020, nor 
detail the impact in terms of energy savings of each new measures put forward. Nonetheless, 
Hungary includes intermediate milestones for 2030 and 2040, energy savings milestones for 
the buildings stock for non-residential and residential buildings. Furthermore, Hungary does 
not  include sufficient  information on related measures for buildings in  terms  of energy  and 
emissions savings, funding, and costs but includes some information on policies and measures 
addressing  deep  renovation,  in  particular  of  worst-performing  buildings  and  for  vulnerable 

170 According to NECP, page 181 of English translation “Following Fit for 55, Member States will be guided by 
an energy renovation of public buildings up to a nearly zero-energy-demand level of 3% of floor area per year 
and an obligation to reduce energy consumption by 1.9% per year, compared to consumption two years earlier. 
As there is no regional governance in Hungary, the basis of the two obligations is essentially the same,  but it is 
also necessary to fulfil them separately. Based on the  state of the Hungarian public institution building stock, 
savings of 18% (-6.6 PJ/10 years) can be achieved by 2030 through cost-optimal renovation, based on a linear 
trajectory. Compared to this, new savings of approximately 14.6 PJ/10 years are required for near-zero energy 
use.” 
171 It seems that it opted for the alternative approach because the target is expressed in energy savings. 
172 Hungary also states that in order to be  in line  with the more  ambitious requirements of the  Directive (EU) 
2023/1791, it would have to achieve cumulative energy savings of 11.6 Mtoe (484.6 PJ). 
173 Except for the EEOS. 
174 Hungary mentioned that EE1st principle will be implemented through “an integral part of planning processes, 
support, funding and investment decisions” in the area of energy policy. The NECP also stated that EE1st principle 
has already been implemented in domestic legislation, however, it did not specify in which specific legislation. 

153 

 
 
 
 
 
 
households,  as  well  as  specific 
decarbonisation of heating and installation of renewables in buildings. 

information  on  policies  and  measures  addressing 

Importantly,  Hungary  announces  that  the  upcoming  National  Building  Renovation  Plan 
(NBRP) from 2025 will provide higher ambition for the building stock, while the measures 
will be reviewed as well. 

2.4  ENERGY SECURITY DIMENSION 

Hungary has  partially addressed  recommendation 13.  The plan does  not  further  explain 
how Hungary will reduce energy imports of Russian fossil fuels and continue encouraging gas 
demand reduction. However, the plan does provide forecasts for the evolution of natural gas 
consumption, which is expected to decrease from 352 PJ in 2019, to 321 PJ by 2030, to 240 PJ 
by 2040 and to 124 PJ by 2050 (WAM scenario), which is a more ambitious trajectory than in 
the draft plan. The plan does not elaborate on the compatibility of its future gas infrastructure 
and the planned new concessions for natural gas extraction with the decarbonisation objectives. 

Energy storage installations, initially mainly battery but increasingly hydro as well, will reach 
500-600  MW  by  2026  and  1  GW  by  2030,  although  the  plan  does  not  include  a  specific 
objective for energy storage deployment. The final plan mentions a flexible tariffs system and 
a specific demand product as potential ways to better exploit demand response potential, and 
new CCGT capacities are envisaged to address electricity system flexibility. 

There  are still few details  on when  alternative solutions  to  Russian oil deliveries will be in 
place.  In  addition,  while  the  final  plan  now  states  that  the  construction  of  a  new  Serbian-
Hungarian oil pipeline is essential to improve security of oil supply, it does not explain how. 
Finally,  the  plan  does  not  describe  the  measures  taken  to  assess  the  adequacy  of  the  oil 
infrastructure in the long run (refinery, oil stocks) with the expected decline in oil demand and 
the move toward lower-carbon alternatives.    

The plan describes some measures to ensure security of supply of nuclear materials, e.g. by 
maintaining sufficient stocks of nuclear fuel. It confirms that an agreement has been concluded 
with an alternative fuel supplier, although this fuel is not yet used or licensed in Hungary. There 
is no information on alternatives to Russian suppliers to ensure diversified supplies of spare 
parts and maintenance services for the VVER reactors in the country. The plan provides some 
information on research activities related to radioactive waste management.  

The final plan mentions that the energy security dimension is impacted by all other dimensions 
(including by the adaptation in the decarbonisation dimension) but does not clearly put forward 
policies and measures to integrate the imperative of climate adaptation in the energy system. It 
only  refers  to  the  National  Adaptation  Strategy  that  contains  measures  supporting  the 
assessment and management of climate risks and energy adaptation, including the assessment 
of climate vulnerability of critical infrastructure elements, such as electricity. 

2.5  INTERNAL ENERGY MARKET DIMENSION 

Hungary  has  partially addressed  recommendation 14. The plan provides clear targets  to 
improve energy system flexibility with a target for storage, which is firm until 2026. There is 
no specific target for demand response, but it is mentioned as an important tool to increase the 

154 

 
 
 
 
 
 
 
flexibility of the Hungarian market. Currently, a large part of this flexibility remains provided 
by  gas-fired  installations.  The  new  measures  include  the  development  of  legislation  for 
aggregators by 2024 to enable a non-discriminatory access to markets and the plan mentions 
other  potential  measures  to  be  investigated  such  as  flexible  tariff  structures  or  specific 
flexibility products.   

The plan defines some forward-looking objectives and targets concerning market integration, 
as part of regulatory obligations such as target to connect to the EU balancing platforms. Some 
objectives, such as the objective to strengthen the connection between intraday and day-ahead 
markets  are  not  substantiated  with  clear  measures.  The  plan  does  not  provide  measures  to 
develop  competitive  wholesale  markets  nor  measures  influencing  market  signals.  Hungary 
provides  measures  facilitating  system  integration  of  renewable  gases  in  the  existing  gas 
network in line with the revised RED II.    

The plan provides measures  to  develop  more competitive retail  markets  and to  increase the 
level of consumer empowerment in the retail market. Those measures relate to the access to 
smart  meters,  where  a  clear  but  low  target  has  been  set,  and  smarter  regulation  for  system 
operators.  

Hungary has partially addressed recommendation 15. Hungary does not have a definition 
of energy poverty. However, the plan specifies the number of households experiencing energy 
poverty,  including  information  on  the  direct  financial  support  given  to  those  requiring 
assistance with their energy costs. However, structural initiatives aimed at improving the retail 
housing market energy efficiency are quite broad and apply to all households, without focusing 
on disadvantaged individuals or those living in energy poverty.  

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Hungary has partially addressed recommendation 16. The plan includes national objectives 
in research, innovation, and competitiveness to deploy clean technologies, although without 
establishing clear pathways to 2030 and 2050. It also describes relevant measures to support 
the decarbonisation of industry and the transition of businesses towards a net-zero economy. 
The plan envisages the adoption of an “Industrial and Technological Action Plan” to support 
domestic manufacturing and competitiveness, but the timeline is unclear. The plan highlights 
the development of twenty net-zero innovation projects by 2030. However, it does not describe 
a predictable and simplified regulatory framework for permitting procedures for manufacturing 
or how access to national funding will be simplified. The plan recognizes the importance of 
digitalisation  in  the  energy  system,  the  development  of  clean  energy-related  skills,  and  the 
strengthening of supply chains for key net-zero components and equipment, without describing 
detailed policies and measures. 

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Hungary has partially addressed recommendation 17. The plan provides an estimate of the 
additional  investment  needs  for  several  sectors  compared  to  a  ‘with  existing  measures’ 
scenario. However, it lacks information on total investment needs and estimates at policy level. 
In  addition,  it  does  not  discuss  how  to  mobilise  private  investment.  Nevertheless,  the  plan 

155 

 
 
 
 
 
details several EU and national funding programmes. The information provided in the plan is 
not  sufficient  to  estimate  whether  there  is  a  potential  financing  gap  with  respect  to  the 
investment needs, or how this would be filled. 

Hungary has partially addressed the recommendation to provide a robust assessment of 
the macroeconomic impact of the planned policies and measures. It includes quantitative 
estimates  of  impacts  on  GDP,  employment,  and  government  revenue.  However,  it  lacks 
information on the methodology used. 

2.8  JUST TRANSITION 

Hungary has partially addressed recommendation 20. The plan provides some references 
to the social, employment and skills impacts of the energy and climate transition, but focuses 
only  on the counties  of Baranya, Heves and Borsod-Abaúj-Zemplén  covered by the TJTPs. 
Moreover, it lacks details on the objectives, policies, and measures, as the form of support, the 
impact of the initiatives, the target groups and the dedicated resources.  

The alignment between the TJTP and the plan is  not sufficient, as for the above-mentioned 
counties  the  coal  phase  out  commitment  is  set  for  2025.  The  plan  does  not  refer  to  the 
commitments to phase out lignite extraction in the two associated open-cast mines (Visonta 
and Bükkábrány). However, it explains that the coal phase-out in Mátra will take longer, due 
to the social, economic, and environmental impacts, and to technological and security of supply 
challenges. 

The plan does not provide the analytical basis needed for the preparation of the Social Climate 
Plan, such as information on the estimated impact of ETS2 and the identification of vulnerable 
groups.  The  plan  does  not  explain  how  the  policy  framework  identified  in  the  NECP  will 
contribute to the preparation of Hungary’s Social Climate Plan nor how the consistency of the 
two plans will be ensured.  

2.9  PUBLIC CONSULTATION 

Hungary has partially addressed recommendation 21. Hungary organised several rounds of 
public consultations for the preparation of the final plan but started very close to the submission 
date of the plan. They were organised online and only on a shortened version of the draft NECP 
in  summer  2023,  and  in  person  in  different  sessions,  conferences,  forums,  and  as  written 
proposals, with  the participation  of relevant  stakeholders  between May and June 2023. The 
National  Environmental  Council,  where  environmental  organizations,  professional  and 
economic interest representatives and academia are represented, was also consulted on the draft 
and final NECP in May 2023 and 2024 respectively. The strategic environmental assessment 
(SEA) of the final NECP took place in summer 2024. 

The plan does not include a detailed summary of the consultations but based on the findings of 
the SEA it lists a few issues to consider during the implementation of the plan. The plan does 
not describe how inputs from stakeholders was integrated but suggests rather generically, that 
the  views  expressed  by  different  actors  during  the  consultations  (on  the  draft  plan)  were 
considered to improve the consistency of the plan. 

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2.10 REGIONAL COOPERATION 

Hungary  has  not  addressed  recommendation  22.  The  plan  includes  initiatives  aiming  at 
increasing Hungary’s engagement with neighbouring Member States and Energy Community 
Contracting Parties. Nevertheless, the plan only makes a very brief mention of its membership 
in the CESEC High-Level Group omitting details about Hungary’s role and objectives within 
the regional cooperation setting. The plan does not identify in detail common challenges and 
shared objectives in terms of interconnectivity, renewables, gases, and internal market. 

The  plan  includes  additional  information  on  the  possible  deployment  of  recharging 
infrastructures in the transport sector under Connecting Europe Facility. Even though Hungary 
refers to regulatory cooperation in implementing the revised RED II, the plan does not elaborate 
on how it aims at establishing the framework for cooperation on joint projects by 2025 in line 
with Article 9 of the revised RED II.  

The  plan  does  not  refer  to  any  progress  nor  efforts  to  be  undertaken  to  sign  five  bilateral 
solidarity arrangements for the security of gas supply with its neighbours (Austria, Slovenia, 
Croatia, Slovakia, and Romania). 

2.11 ANALYTICAL BASIS 

The plan provides a description of the analytical framework with projections reaching 2050, 
relying on quantitative modelling. However, it lacks information on the methodology used.  

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

Hungary has  not addressed  recommendation 18. The final  NECP partially addresses the 
Commission’s recommendation and largely covers the main reforms and investments of the 
Recovery and Resilience Plan (RRP) that contribute to implementing the objectives, targets 
and  contributions  of  the  Energy  Union.  The  final  updated  NECP  still  does  not  refer  to  the 
reform on improving transparency, predictability and availability of the grid connection, which 
is a relevant climate and energy reform of the RRP and its REPowerEU chapter. Most of the 
RRP measures are included in the plan but they are not linked to the RRP.  The plan still fails 
to elaborate on how the RRP and REPowerEU chapter investments and reforms will contribute 
to achieving the quantitative targets included in the NECP.  

3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

Hungary needs to swiftly proceed with implementing its final updated National Energy and 
Climate Plan. Hungary is invited to pay particular attention to the following main elements: 

•  On ESR, implement in a timely manner additional policies and measures towards the ESR 
target,  as  a  significant  part  of  projected  emissions  reductions  in  Hungary  is  driven  by 
measures that are not yet fully in place.  

157 

 
 
 
 
 
•  On  agriculture,  support  practices  leading  to  more  efficient  input  use,  harnessing  the 
potential  of  precision  farming,  low  input  and  agro-ecological  methods,  adopting  low 
emission feeding strategies, improving manure management, increasing the use of energy 
from renewable sources and energy efficiency, improving the management of agricultural 
residues, grassland and forest land.  

•  On adaptation,  carry  out  a comprehensive vulnerability assessment of the network  and 
infrastructure,  based  on  different  climate  scenarios,  to  identify  and  address  potential 
weaknesses of the energy system.  

•  Analyse  the  impact  of  postponing  the  commitment  to  phase  out  fossil  fuels  to  2029, 
including for open cast mines.  Develop a roadmap with specific measures to phase out all 
fossil fuel subsidies. 

•  On industry, develop  a more comprehensive plan for increasing  the use  of renewables, 
including  by identifying  concrete measures  to promote renewable hydrogen  and  CCUS, 
increasing energy efficiency, and supporting skills development. 

•  On  renewable  energy,  put  in  place  measures  to  achieve  the  higher  ambition  for 
renewables  by  2030  that  aligns  with  the  EU’s  collective  target  for  renewable  energy. 
Develop  a  more  comprehensive  plan  for  increasing  the  use  of  renewables  in  buildings. 
Identify  renewables  acceleration  areas  which  will  be  subject  to  the  new  permitting 
procedures, and establish a framework for renewable power purchase agreements, thereby 
providing certainty to market actors. Identify innovative renewable energy technologies 
in view of achieving the indicative target of 5% set in the revised RED II. 

•  On energy efficiency, put in place measures to achieve the higher ambition by 2030.  
•  On  buildings,  ensure  ambitious  depth  of  renovation  of  the  overall  building  stock, 
specifically  addressing  deep  renovation  of  worst  performing  buildings.  Increase  the 
availability and accessibility of technical assistance and one stop shops to citizens. Design 
and implement ambitious reskilling programs to address construction labour shortages. 
•  On  transport,  further  promote  a  modal  shift  to  public  transport  by  investing  in 

infrastructure and policy changes.  

•  On nuclear energy, continue efforts to diversify nuclear fuel supplies, and ensure the long-

term supply of spare parts and maintenance services. 

•  Develop a more comprehensive just transition strategy, that includes a robust analysis of 
social, employment and skills  impacts of the transition and allocates sufficient  financial 
resources.  

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Malta 

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Malta’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

2022: +43.6% 
2023: +30.6%175 

-19% 

NECP:  
+29.4% 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for 
additional net GHG 
removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 

Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

10.7%% 
(SHARES) 
10% 
(target) 

National contribution for 
energy efficiency: 

2022: Reported 
net emissions of 
0.001 Mt CO2 
eq.  

-0.002 Mt CO2 
eq. (additional 
removal 
target) 

2023: 15.1% 

24.5% 

Primary energy 
consumption  

0.8 Mtoe 

2023: 0.91 Mtoe 

0.964 Mtoe 

Insufficient 
ambition based on 
projections: A gap 
of 0.003 Mt CO2 
eq compared to 
the 2030 target 

 MT contribution 
of 24.5% is below 
the 28% required 
according to the 
formula set out in 
Annex II of the 
Governance 
Regulation176 

MT primary 
energy 
consumption 
contribution of 
0.964 Mtoe is not 
in line with the 
EED recast 
Annex I formula 
results: 0.83 Mtoe 
(Reference 
Scenario) or 0.76 
Mtoe (Updated 

175  The ESR emissions in 2022 are based on 2024 final GHG inventory reports, and 2023 emissions are based on 
2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as set 
out in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions 
for 2021-2025 will only be established in 2027 after a comprehensive review. 

176 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 

p. 1–77 (‘Governance Regulation’). 

159 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
Final energy consumption 

0.6 Mtoe 

2023: 0.72 Mtoe 

0.803 Mtoe 

Level of electricity 
interconnectivity (%177) 

31.0% 

2024: 39.5% 

15% 

Source: Eurostat; Malta’s draft updated national energy and climate plan 

Reference 
Scenario). 

MT final energy 
consumption 
contribution of 
0.803 Mtoe is not 
in line with the 
national 
contribution of 
0.68 Mtoe 
submitted by the 
Commission. 

Malta surpasses 
the EU-wide 
interconnectivity 
target 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In December 2023, the Commission published a thorough assessment of Malta’s draft updated 
NECP and provided recommendations178 for the preparation of the final updated NECP. Malta 
submitted its final updated NECP on 7 January 2025, over six months after the deadline of 30 
June 2024.179 

2.1  DECARBONISATION 

Malta  expects  to  decrease  total  GHG  emissions  (including  LULUCF  and  excluding 
international aviation) by 32% in 2030 compared to 1990. 

2.1.1  Effort Sharing Regulation 
Malta  has  partially  addressed  recommendation  1.  The  final  NECP  provides  insufficient 
details on how Malta will meet its ESR target of -19% by 2030 compared to 2005.  

The plan provides updated projections that mark an improvement compared to the previous 
submission  under  the  National  Energy  and  Climate  progress  reports  (March  2023) 180,  but 
showing that the existing policies and measures will lead to an increase of ESR emissions by 
29.4% in 2030 compared to 2005, a gap of over 48 percentage points to the national target. In 
2023, GHG emissions from ESR sectors represented 62.6% of the total in Malta (expected to 
be  59%  in  2030) 181,  with  transport  representing  the  largest  share.  The  plan  mentions  the 
availability of LULUCF flexibilities to attain ETS objectives. 

177  Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2024). The 2030 level 
represents the general interconnectivity target of 15%. 
178   SWD(2023) 920 final, and Commission Recommendation of 18 December 2023, C/2023/9610. 
179 Article 14(2) of Governance Regulation. 
180 The draft NECP did not include projections on GHG emissions from the sectors covered by ESR. 
181 The  2023  emissions  are  based  on  2024  approximated  inventory  reports  and  2030  is  based  on  reporting  of 
greenhouse gas projections (Article 18 of the Governance Regulation). 

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The  final  plan  includes  little  extra  information  on  the  policies  and  measures  and  still  lacks 
details on their scope, timeline and expected impact on GHG emissions. For what concerns 
transport,  over  the  period  2015-2022  emissions  showed  an  annual  percentage  increase  of 
3.1%182, but  are expected to decrease  relatively slowly  (1.9% per year) in  the period 2022-
2030183. The plan includes only generic information on how Malta plans to address this issue.  

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings,  road  transport  and  additional  sectors  (ETS2).  The  scenario  projections  do  not 
account for the effect of ETS2, and do not quantify the impact of ETS2 in achieving the ESR 
target. 

On  waste,  the  measures  to  reduce  methane  emissions,  such  as  gas  capture  equipment  for 
existing  landfills,  may  not  achieve  significant  reductions,  and  do  not  address  Malta's  high 
landfilling rate, with the organic waste processing plants limited capacity of 74,000 tonnes per 
year  being  significantly  outpaced  by  the  257,974  tonnes  landfilled  (2019),  highlighting  the 
need for more effective waste reduction and management strategies. 

The plan does not present any mitigation measures for F-gases from industrial processes and 
product use. It mentions only vaguely the end-of-life treatment of HFCs and does not envisage 
the use of climate-friendly alternatives to HFCs with a high GWP in the air conditioning and 
cooling sector.  

2.1.2  LULUCF 
Malta has not addressed recommendation 2. The LULUCF sector in Malta accounted for 
less than 1% of Malta’s total GHG emissions in 2022.  According to the LULUCF Regulation, 
Malta has to improve its net removals by  -0.002 Mt CO2eq in 2030 compared to its yearly 
average in the 2016-2018 reference period. According to 2022 figures, the LULUCF sector in 
Malta produced net emissions of 0.001 MtCO2eq. in 2022. Moreover, taking into account its 
projections for 2030, Malta will still have a gap of 0.003 MtCO2eq. in 2030. The plan indicates 
that for LULUCF there are no additional policies compared to the baseline scenario.  

The plan does not provide sufficient information on how public funding (CAP, State aid) and 
private financing through carbon farming schemes are used to reach the LULUCF target. The 
plan  also  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. 

Overall,  based  on  the  available  information,  Malta  does  not  design  sufficiently  effective 
policies to support the land sector and the achievement of the LULUCF target. 

2.1.3  Carbon Capture and Storage 
Malta  did  not  receive  a  recommendation  on  CCUS.  The  NECP  does  not  include  a  CCUS 
strategy. 

2.1.4  Adaptation 
Malta has not addressed recommendation 3. The plan refers to the forthcoming ‘Climate 
Vulnerability Risk Assessment of the Maltese Economy’, which was still not available at the 

182 Compound annual growth rate. 
183 Compound annual growth rate. Source: EEA. 

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time of publishing this document. Therefore, it does not analyse climate vulnerabilities and 
risks.  It  is  also  short  of  quantifiable  assessment  of  impacts.  The  plan  lacks  for  most  parts 
adaptation policies and measures in the relevant Energy Union dimensions. However, Malta 
has set up a dedicated Climate Action Authority in 2024 to implement measures to combat, 
mitigate, and adapt to climate change. 

The plan does not outline the link to the specific Energy Union objectives and policies that 
adaptation policies and measures are meant to support. The impacts and benefits of adaptation 
policies on other Energy Union objectives have generally not been quantified. The plan does 
not set out additional adaptation policies and measures to support the achievement of national 
objectives, targets and contributions under the Energy Union.  

The plan does not address the consequences of climate change on future water availability 
and its implications on the energy sector. Nonetheless, it refers to ongoing general actions on 
rainwater capture and green infrastructure against surface water run-off. 

2.1.5  Fossil Fuels 
Malta has not addressed recommendation 17. The plan states that Malta is committed to 
accelerate efforts towards the phase-out of inefficient fossil fuel subsidies. However, currently 
there are no plans to phase out energy subsidies, due to its insularity.   

2.2  RENEWABLES  

Malta  has  partially  addressed  recommendation  4.  Malta  has  significantly  increased  its 
renewable energy contribution for 2030 to 24.5% of gross final energy consumption. However, 
this contribution remains below 28%, resulting from the formula of Annex II of the Governance 
Regulation. Indicative trajectories for 2025 (16.5%) and for 2027 (20.7%) were also provided 
but they are below the reference points calculated in line with the EU 2030 renewable energy 
target of 42.5% (18% for 2025 and 22% for 2027 respectively). 

Malta  has  partially  addressed  recommendation  5.  Projections  for  the  deployment  of 
renewable energy technologies are provided. The plan does not provide an indicative target for 
the  deployment  of  innovative  renewable  energy  technologies  for  2030.  Malta  refers  to  the 
sectoral targets of the ‘revised RED II’184. However, the plan does not mention the specific 
targets for buildings, industry and the heating and cooling sector, and the minimum level of 
renewable fuels of non-biological origin (RFNBOs) in industry by 2030 and sub-targets for 
advanced biofuels and RFNBOs in transport by 2030. The plan does not include an indicative 
top-up for heating and cooling in line with Annex IA of the revised RED II.  

Malta has partially addressed recommendation 6. Malta refers to support schemes for solar 
PVs, but without quantifying their impacts and contribution towards achieving Malta’s target 
of  24.5%  renewables  for  2030.  The  recommendations  related  to  accelerated  permitting  and 
renewable  acceleration  areas  have  been  addressed.  Malta  indicates  that  a  study  is  currently 
being carried out to address the recommendation on power purchase agreements and energy 

184 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  

162 

 
 
 
 
 
 
communities.  The  plan  includes  measures  to  promote  the  sustainable  production  of 
biogas/biomethane.  

Malta has partially addressed recommendation 7. For most of the policies and measures the 
plan does not provide information on the expected timeline and procedural steps as regards 
transposing and implementing the provisions of the revised RED II. 

2.3  ENERGY EFFICIENCY DIMENSION  

Malta  has  not  addressed  recommendation  8.  Malta  included  an  indicative  national 
contribution of 0.8 Mtoe to the Union’s binding final energy consumption target for 2030. This 
contribution is not in line with Article 4 of Directive (EU) 2023/1791 (‘EED recast’)185, nor 
equal to the corrected indicative national contribution that the Commission submitted to Malta 
in March 2024 under Article 4(5) of that Directive. There is still a gap of 16.9% compared to 
the  indicative  results  of  the  2020  reference  scenario  and  a  gap  of  22.4%  compared  to  the 
indicative results of the updated 2020 reference scenario.  

Malta included an indicative national contribution to the Union’s indicative primary energy 
consumption target for 2030 of 1.0 Mtoe for primary energy consumption. This contribution is 
not in line with Article 4 of EED Recast. There is still a gap of 16.2% compared to the target 
calculated with respect to the indicative results of the 2020 reference scenario, and a gap of 
26.8% compared to the target calculated with respect to the indicative results updated 2020 
reference scenario.  

Malta did not include the amount of energy consumption reduction per year to be achieved by 
all public bodies. Malta did not report the total floor area of heated and cooled buildings owned 
by public bodies to be renovated yearly - nor the corresponding yearly energy savings to be 
achieved and it also did not specify if opted for alternative or default approach. The plan sets 
out some policies and measures to achieve the reduction of energy consumption from public 
bodies and the renovation of public buildings.  

Malta has partially addressed recommendation 9. The plan sets out policies and measures 
to achieve the national contributions on energy efficiency, but it did not quantify the expected 
energy savings and the contribution of each of the reported measures. The plan specifies robust 
energy efficiency financing programmes and support schemes, including financial instruments 
and  public  guarantees,  able  to  mobilise  private  investments  and  additional  co-financing. 
However,  Malta  does  not  report  existing  policy  measures  to  promote  the  uptake  of  energy 
efficiency  lending  products  and  innovative  financing  schemes  such  as  On-Bill  and  On-Tax 
schemes,  Energy  Performance  Contractors,  ESCOs  and  third-party  financing2.  Malta  has 
established a National Energy Efficiency Fund but the plan does not elaborate on its role in 
helping deliver Malta’s energy efficiency contributions, and it also does not include the use of 
financial instruments within the Fund.  

Malta has partially addressed recommendation 10. The plan does not include an updated 
ambition level to ensure a highly energy efficient and decarbonised national building stock and 
to  transform  existing  buildings  into  zero-emission  buildings  by  2050.  Malta  included 

185 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 

163 

 
 
 
 
 
 
intermediate  milestones  for  2030  and  2040  for  the  renovation  of  both  residential  and  non-
residential buildings. The plan includes energy savings milestones for the buildings stock but 
does not detail the impact in terms of energy and emission savings of each new measures put 
forward and it does not include sufficient information in terms of funding and costs. However, 
the NECP provides specific information on policies and measures addressing deep renovation, 
with  a  specific  focus  on  vulnerable  consumers,  as  well  as  decarbonisation  of  heating  or 
installation of renewables in buildings.  

2.4  ENERGY SECURITY DIMENSION 

Malta has partially addressed recommendation 11. Gross inland consumption of natural gas 
is expected to decrease from 318.2 ktoe in 2020 to 201.6 ktoe in 2030 (WAM scenario), driven 
mainly by the reduced electricity generation from natural gas. 

The plan sets an objective of developing two utility scale battery energy storage systems before 
2030. The first one, located inside the A Station in Marsa, with a capacity of 8MW/20 MWh 
and the second, 32 MW/64 MWh located within the Delimara power station. There are also 
incentives  for  the  deployment  of  behind-the-meter  battery  storage  linked  to  domestic  PV 
systems.  Additionally, the resilience of the electricity system  will be enhanced by a second 
interconnector with Italy. 

As regards the imperative of climate adaptation of the energy system, the final plan includes 
‘energy’  under  the  47  sector-specific  actions  under  the  Low  Carbon  Development  Strategy 
(LCDS), but it still contains few details on concrete planned steps. 

The plan does not assess the adequacy of the oil stocks of which a majority is held as tickets186, 
with the expected oil demand decline and the move to lower-carbon alternatives.    

2.5  INTERNAL ENERGY MARKET DIMENSION 

Malta  has  partially  addressed  recommendation  12  by  providing  targets  to  improve  the 
flexibility of the energy system. Although the plan elaborates on the quantification of flexibility 
needs, it does not set clear targets and objectives for demand response, storage, and flexibility. 
While Malta acknowledges the importance of demand response and flexibility, the  Member 
State’s current market structure, particularly the lack of price signals and a liquid wholesale 
electricity market, limits the development of demand response. The updated plan includes an 
assessment of potential solutions but does not provide concrete, quantified targets. 

The  plan  does  include  measures  to  enhance  flexibility  and  enable  a  non-discriminatory 
participation of new flexibility services. It outlines initiatives such as the deployment of battery 
energy  storage  systems  vehicle-to-grid  technology,  and  the  expansion  of  smart  grid 
technologies.  Additionally,  Malta  has  implemented  financial  support  schemes  to  encourage 
behind-the-meter  battery  storage  and  demand-side  solutions.  However,  the  absence  of  real-
time price signals remains a barrier to fully enabling demand response participation. The plan 

186 Tickets are stockholding arrangements under which the seller agrees to hold (or reserve) an amount of oil on 
behalf of the buyer, in return for an agreed fee. https://www.iea.org/data-and-statistics/data-tools/oil-stocks-of-
iea-countries  

164 

 
 
 
 
 
 
 
does not provide information on specific measures to facilitate energy system integration  in 
accordance with Article 20a the revised RED II. Regarding consumer empowerment, the plan 
outlines  several  measures  including  support  for  self-consumption  and  further  roll-out  of 
second-generation  smart  meters.  However,  regulated  electricity  provides  little  incentive  for 
consumers to play an active role in the market. 

Malta  has  partially  addressed  recommendation  13.  The  updated  NECP  includes  an 
assessment of the situation regarding energy poor and vulnerable households in the country. It 
also set outs a comprehensive list of existing and planned measures to address energy poverty, 
including regulated tariffs, subsidy schemes, energy efficiency measures, personalised energy 
advise for vulnerable households and programmes for replacement of inefficient appliances. 
Furthermore,  Malta  launched  a  consultation  on  the  so-called  National  Strategy  for  Poverty 
Reduction  and  Social  Inclusion  2025-2035,  which  also  addresses  energy  poverty.  The  plan 
however does not indicate any specific measurable targets for energy poverty reduction.  

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Malta has not addressed recommendation 14. The plan lacks a comprehensive approach, 
including  targets  to  support  research,  innovation  and  competitiveness  in  clean  energy 
technologies,  the  manufacturing  of  clean  energy  technologies  and  equipment,  and  the 
digitalisation of the energy value chain. The plan does not set a pathway to 2030 and 2050, nor 
measures to  promote  the  development  of  net-zero  projects  including  those  relevant  for  the 
energy intensive industries. It does not describe how it will ensure a predictable and simplified 
regulatory framework for permitting procedures for manufacturing or how access to national 
funding will be simplified where needed. Although investing in education in general is part of 
the Vision Malta 2050 and the National Reform Programme 2024, the plan does not include 
information on policies and measures for the development of clean energy-related skills and 
does not include measures to facilitate resilient and sustainable supply chains of key net-zero 
components and equipment.  

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Malta  has  not  addressed  recommendation  15.  The  plan  does  not  provide  estimates  of 
investment needs per sector and does not distinguish between private and public investments. 
Funding sources are briefly described, but neither per sector nor at the level of the planned 
initiatives. The plan does not discuss measures and initiatives to mobilise private investments. 
Overall,  the  information  provided  in  the  plan  is  not  sufficient  to  assess  whether  there  is  a 
potential financing gap compared to the investment needs, or how this would be filled.  

Malta has not addressed the recommendation to provide a robust quantitative assessment 
of  the  macroeconomic  impact  of  the  planned  policies  and  measures.  The  plan  provides  a 
qualitative analysis of possible macroeconomic impacts. 

2.8  JUST TRANSITION 

Malta has partially addressed recommendation 19. The plan provides information on the 
impact  of  the  transition  to  climate  neutrality,  targeting  sectors  such  as  energy,  buildings, 
transport and waste management, and analysing skills, employment and other social aspects. 

165 

 
 
 
 
 
However, it does not sufficiently addresses the impacts on vulnerable groups. . Moreover, the 
plan does not specify the form of support, the impact of initiatives or the resources available, 
except for the Just Transition Fund.  

The plan partially provides the analytical basis needed for the preparation of the Social Climate 
Plan, such as information on the identification of vulnerable groups. The plan partially explains 
how the policy framework identified in the NECP will contribute to the preparation of Malta’s 
Social Climate Plan but does not explain how the consistency of the two plans will be ensured.  

2.9  PUBLIC CONSULTATION 

Malta has partially addressed recommendation 20. The plan provides very little information 
on how the public consultation on the draft and final updated NECP was organised (rounds of 
consultation, their duration and stakeholders involved are not described). It only states that key 
stakeholders were involved from the early stages of the NECP update, and a public consultation 
was  later  conducted  to  gather  broader  input  from  society,  through  the  government’s  online 
platform  with  a  questionnaire.  However,  the  plan  describes  in  a  greater  extend  other 
consultation  processes  on  key  thematic  policies  relevant  to  the  NECP.  The  plan  provides  a 
summary of the main views, as well as information on other consultation processes on topics 
of relevance for the preparation of the NECP. However, it does not describe how the final plan 
integrated the inputs and changes suggested from stakeholders. 

2.10 REGIONAL COOPERATION 

Malta  has  not  addressed  recommendation  21. The  importance  of  regional  cooperation  is 
mentioned  as  well  as  the  ‘Med9’  Energy  Minister’s  meeting  of  18  May  2023,  where 
Mediterranean  Member  States  pledged  to  transform  the  Mediterranean  region  into  a  green 
energy hub. The plan however does not elaborate on how Malta intends to establish an enabling 
framework  for  cooperation  on  joint  projects  with  one  or  more  other  Member  States  for  the 
production of renewable energy in line the revised RED II. 

2.11 ANALYTICAL BASIS 

Malta  has  addressed  recommendation  18.  The  plan  provides  projections  for  the  energy 
system and GHG emissions for WEM and WAM scenarios, although not until 2040 for several 
indicators. 

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

Malta has addressed recommendation 16. The plan covers sufficiently the main reforms and 
investments of the Recovery and Resilience Plan (RRP) that contribute to implementing the 
objectives, targets, and contributions of the Energy Union. 

166 

 
 
 
 
 
3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

The  Commission  encourages  Malta  to  ensure  a  timely  and  complete  implementation  of  the 
final updated NECP. Malta is invited to pay particular attention to the following main elements:   

•  Closely monitor the impacts  of the policies included in  the plan on emission  reductions 
under  the  ESR  and  increase  efforts  across  all  effort  sharing  sectors.  Explore  available 
flexibilities  to  comply  with  ESR  obligations. Foster  the  uptake  of  climate-friendly 
alternatives to HFCs in the air conditioning and cooling sector.  

•  On adaptation, finalise and use the results of the ‘Climate Vulnerability Risk Assessment 
of the Maltese Economy’ to assess relevant climate vulnerabilities and risks for the national 
objectives, targets, and contributions and the policies and measures in the different Energy 
Union  dimensions.  That  would  enable  better  outlining  and  quantifying  the  link  to  the 
specific objectives  that adaptation  policies are meant  to  support. The assessment  should 
cover  all  relevant  water  user  sectors  to  ensure  a  comprehensive  approach  to  water 
management. Set additional adaptation policies and measures in sufficient detail.  

•  Clarify fossil fuel subsidies and set timeline to gradually phase them out. Carbon pricing 
and targeted social support can help maintain affordability while meeting climate goals.  
•  Enhance energy system integration, particularly in  electricity, transport, and buildings. 
Policies  should  support  demand-response  programs,  energy  storage  deployment,  and 
digitalization of energy infrastructure. Set up a framework promoting cross-sectoral energy 
efficiency  to  help  maximize  the  benefits  of  increased  renewable  deployment.  Introduce 
dynamic electricity pricing to improve demand-side flexibility. 

•  Develop a comprehensive plan with dedicated measures to achieve the higher ambition for 
the  deployment  of  renewables  by  2030  that  aligns  with  the  EU’s  collective  target  for 
renewable energy including the deployment of innovative renewable energy technologies. 
Put in place measures for renewables uptake in buildings. Streamline permitting processes 
and  regulatory  frameworks  to  facilitate  investment,  particularly  in  offshore  renewables, 
given  that  spatial  constraints  remain  a  challenge.  Accelerate  the  deployment  of  floating 
solar PV and offshore wind projects, notably by ensuring policy certainty.  

•  Expand charging infrastructure for EVs and reduce car dependency through for example 

congestion pricing and improved public transit options. 

•  On  energy  efficiency,  put  in  place  measures  to  achieve  the  higher  ambition  for  energy 

efficiency by 2030 and to target the energy consumption of the public sector. 

•  On industry, put in place measures aimed at promoting renewables uptake, in particular 

for renewable hydrogen.  

•  On  buildings,  provide  further  efforts  to  improve  energy  efficiency,  particularly  in 
increasing renovation rates and encouraging deep retrofits with a focus on the residential 
building  stock.  Prioritise  electrification  of  heating  and  deployment  of  heat  pumps  and 
address  electricity-to-gas  price  disparities.  Speed  up  implementation  of  the  NECP  by 
strengthening regulatory enforcement and increasing technical assistance. 

•  Expand  investment  in  clean  energy  research  and  development.  Strengthening  public-
private partnerships and aligning with EU research frameworks will accelerate innovation. 

167 

 
 
 
 
 
•  Develop a more comprehensive just transition strategy, that includes upskilling/reskilling 

measures and allocates appropriate financial resources.  

168 

 
 
 
 
 
Netherlands 

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of the Netherland’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

2022: -33.8% 
2023: -34.4%187 

-48% 

Reported net 
emissions of 5.1 
Mt CO2 eq. in 
2022 

0.44 MtCO2 
eq. (additional 
removal 
target) 

2023: 17.2% 

32-42% 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for net 
GHG removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 

Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

14% 
(SHARES) 
14% 
(target) 

National contribution for 
energy efficiency: 

Primary 
consumption  

energy 

60.70 
Mtoe 

2023:  53.8 
Mtoe 

46.22 Mtoe 

NECP:  
-38.7%. 
However, NL is 
expected to meet 
the 2030 target 
with ESR 
flexibilities 

NL is expected to 
meet its target 
based on the latest 
projections: 
overachievement 
by – 1.22 Mt CO2 
eq 

NL contribution 
to the EU target is 
a share of 32-
42%. This range 
includes the 39% 
required 
according to the 
formula set out in 
Annex II of the 
Governance 
Regulation188. 

NL primary 
energy 
consumption 
contribution is 
46.22 Mtoe. EED 
recast Annex I 
formula results: 
46.21 Mtoe 
(Reference 
Scenario) or 45.30 

187  The ESR emissions in 2022 are based on 2024 final GHG inventory reports, and 2023 emissions are based on 
2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as set out 
in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions for 2021-
2025 will only be established in 2027 after a comprehensive review. 
188 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’). 

169 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
Final energy consumption 

52.2 Mtoe 

2023: 41.0 Mtoe 

38.4 Mtoe 

Level of electricity 
interconnectivity (%)189 

25.9% 

2024: 10.3% 

15% 

Source: Eurostat; the Netherland’s final updated national energy and climate plan 

Mtoe (Updated 
Reference 
Scenario) 

NL final energy 
consumption 
contribution of 
38.4 Mtoe is in 
line with the 
national 
contribution of 
38.4 Mtoe 
submitted by the 
Commission. 

NL is below the 
EU-wide 
interconnectivity 
target. 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In December 2023, the Commission published a thorough assessment of the Netherland’s draft 
updated  NECP  and  provided  recommendations 190 for  the  preparation  of  the  final  updated 
NECP. The Netherlands submitted its final updated NECP on 24 June 2024, in line with the 
deadline of 30 June 2024.191 

A new Dutch government was sworn in on 2 July 2024, shortly after the submission of the final 
updated NECP. The plan thus includes a disclaimer that several policies included in the NECP 
will be adjusted to align with the new administration’s plans. These changes are discussed in 
the latest Climate and Energy Outlook (KEV 2024)192 published in October 2024, with specific 
details of policy changes are still being elaborated.   

2.1  DECARBONISATION 

The Netherlands expects to decrease total GHG emissions (including LULUCF and excluding 
international aviation) by between 46% to 57% in 2030 compared to 1990. However, the most 
recent update of the KEV 2024 points to a lower expected emissions reduction in 2030 of only 
44% to 52% compared to 1990193. The Netherlands has committed to bring net GHG emissions 
to zero by 2050 in its updated Climate Act of July 2023.  

189  Calculated by the European Commission based on the ENTSO-E data (Winter Outlook 2024). The 2030 level 
represents the general interconnectivity target of 15%. 
190 SWD(2023) 921 final, and Commission Recommendation of 18 December 2023, C/2023/9611. 
191 Article 14(2) of Governance Regulation. 
192 Annual report that provides an assessment of the Netherlands' progress toward achieving its climate and energy 
goals, including emission reductions and the transition to a sustainable energy system. The KEV 2024 provides 
an update of the KEV (2022 and 2023) projections that were used in the Final Updated NECP. Link: Klimaat- en 
Energieverkenning 2024 | Planbureau voor de Leefomgeving 

193 Climate and Energy Outlook 2024 | Netherlands Environmental Assessment Agency 

170 

 
 
 
 
 
 
 
 Effort Sharing Regulation 

2.1.1 
The  Netherlands  has  partially  addressed  recommendation  1.  The  final  NECP  provides 
information  on  how  the  Netherlands  will  work  to  meet  its  ESR  target  of  -48%  by  2030 
compared to 2005. 

The plan provides updated projections based on the KEV 2023, showing that with existing and 
planned policies and measures The Netherlands will reach ESR emission reductions of -38.7% 
in 2030 compared to 2005, 9.3 percentage short of their -48% target. However, the more recent 
KEV2024 provides a 2030 ESR projection that result in a 46.7% reduction compared with 2005 
emissions.  The  Netherlands  is  on  track  to  stay  within  its  cumulative  emissions  cap  for  the 
period 2021-2030. While the Netherlands expects its GHG emissions to be above its annual 
emission allocations towards the end of the decade, overachievements in the earlier years will 
be sufficient to cover for these shortfalls in accordance with Article 5 of the ESR.  In 2023, 
GHG emissions from ESR sectors represented 59% of the total in the Netherlands (expected to 
be 65% in 2030194), with buildings and transport representing the largest shares.195   

The  final  plan  complemented  the  information  on  the  policies  and  measures  provided  in  the 
draft, but it would be useful to have a clearer description of their scope, timeline and expected 
greenhouse gas reduction impact. For transport, the projections indicate a slowdown in GHG 
emissions reduction until 2030, with a projected average decrease of 0.5% per year from 2022 
to 2030, in contrast to a 2.0% decline recorded between 2015 and 2022.  For buildings, the 
projections  also  describe a reduced average annual  decline in  GHG  emissions  in  the period 
2022-2030 compared to the pace attained in the period 2015-2022 (from -3.0% to -1.0%).196  

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings, road transport and additional sectors (ETS2). The scenario projections account for 
the effect of ETS2 but do not quantify its impact in achieving the ESR target. 

On agriculture, the plan does not provide sufficient detail on how to bridge the gap towards 
the national sectoral objective. 

2.1.2  LULUCF 
The Netherlands has addressed recommendation 3. The LULUCF generates net emissions, 
representing roughly 3% of the total GHG emissions in the Netherlands in 2022. According to 
2022 figures, the Netherlands has improved its performance by 0.3MtCO2eq. in comparison to 
its yearly average in the 2016-2018 reference period. According to the LULUCF Regulation, 
the Netherlands has to  enhance its net  removals by  -0.4 MtCO2eq in  2030 compared to  the 
reference period.  In its 2030 projections the Netherlands overachieves its LULUCF target by 
-1.22  MtCO2eq  in  2030.  A  possible  overachievement  of  the  2030  LULUCF  target  can,  if 
necessary, be used to compensate for any shortfall in meeting the 2030 ESR target. The plan 
provides sufficient information on how public funding (CAP, state aid) and private financing 
through carbon farming schemes are used to reach the LULUCF target. The draft also clarifies 
the status and progress in ensuring higher tier levels and geographically explicit datasets needed 
to ensure the robustness of net removal estimates. 

194 The 2023 emissions are based on 2024 approximated inventory reports. 
195 Based on annual reporting of final greenhouse gas inventory data (Article 26 of the Governance Regulation). 
196 Compound annual growth rate 

171 

 
 
 
 
 
 
2.1.3  Carbon Capture and Storage 
The Netherlands has addressed recommendation 2. The plan provides a strategy on Carbon 
Capture and Storage (CCS). It contains an assessment of the total theoretical storage capacity 
of 1,600 MtCO2. The actual commercial capacity is to be further assessed. The Netherlands 
aims at an annual injection capacity of 2.5 MtCO2 per year from 2026, through the Porthos 
project. For 2030, it is estimated that 10-15 Mtpa of CO2 will be captured and permanently 
stored. The plans for CCS are robust, with complete legislation in place and support schemes.  

2.1.4  Adaptation 
The Netherlands has partially addressed recommendation 4. The plan refers to the National 
Adaptation  Strategy  (NAS)  and  the  National  Adaptation  Implementation  Programme  to 
respond  to  the  recommendation,  acknowledging  the  importance  of  integrating  adaptation 
planning. It partially embeds adaptation policies and measures in the relevant Energy Union 
dimensions. 

The plan contains a partial analysis of climate vulnerabilities and risks. It contains a brief 
description of the outcome of the new national climate scenarios, and information on the impact 
of planned polices and measures on the energy system and GHG emissions. However, the plan 
is short of quantifiable assessment of impacts. 

The plan partially outlines the links to the specific Energy Union objectives and policies that 
adaptation policies and measures are meant to support. It provides a brief description of the 
activities  of  the  national  government  in  the  field  of  climate  adaptation,  referring  to  the 
upcoming  NAS,  the  Delta  Programme  and  the  National  Adaptation  Implementation 
Programme. However, the impacts and benefits of adaptation policies on other Energy Union 
objectives have generally not been quantified.  

The  plan  sets  out  some  additional  adaptation  policies  and  measures  to  support  the 
achievement of national objectives, targets and contributions under the Energy Union, notably 
the  climate  scenarios,  the  upcoming  climate  risk  assessment  and  the  climate  adaptation 
strategy. However, this overview misses specific links between adaptation policies and the five 
dimensions  of the Energy Union. The  information on  adaptation  measures  is insufficient  to 
assess their financing, implementation, timing and scalability.  

2.1.5  Fossil Fuels 
The  Netherlands  has  partially  addressed  recommendation  19.  The  plan  declares  the 
intention to phase out of fossil fuel subsidies, indicating that the Netherlands has phased out 
several fossil fuel subsidy schemes (e.g. the refund scheme for energy-intensive businesses for 
the energy tax on electricity) and that it has taken steps to phase out others (e.g. the reduced 
tax rate on natural gas for glasshouse horticulture and the input exemption from the energy tax 
on natural gas). However, it does not provide a clear commitment or a roadmap.  

2.2  RENEWABLES  

The  Netherlands  has  partially  addressed  recommendation  5.  The  updated  Dutch 
contribution (based on KEV2023 scenario, assuming additional measures) to the EU renewable 
energy  target  is  a  share  between  32-42%  of  gross  final  energy  consumption  by  2030.  The 
Netherlands underlines that based on the new policies announced in 2024, the level of 39% (in 
line  with  the  formula  of  Annex  II  of  the  Governance  Regulation)  is  within  the  range.  The 

172 

 
 
 
 
 
Netherlands does not provide the indicative trajectory for the years 2025 and 2027 arguing that 
the trajectory is not linear. As regards the 2021 renewables baseline –the Netherlands explains 
that in 2021, there was a deficit compared to the baseline as the (domestic) share of renewable 
energy reached 13%, but in 2022 the share reached 15%, i.e. above the 2020 baseline target.  

The  Netherlands  has  partially  addressed  recommendation  6.  The  Netherlands  provides 
projections for the deployment of offshore wind beyond 2030. The plan also refers to plans to 
deploy innovative technologies (e.g. solar power at sea, offshore electrolysis), even though the 
Netherlands  does  not  set  a  specific  indicative  target  for  innovative  renewable  energy 
technologies by 2030 in line with Directive (EU) 2018/2001 (the ‘revised RED II’)197. 

Regarding  specific  targets  to  achieve  the  indicative  sub-targets  in  industry  for  2030,  the 
Netherlands indicates a share of 0.6% to 1.3% per year by 2030. The final plan also clarifies 
that 42% of renewable fuels of non-biological origin (RFNBOs) in industry would equal 81 PJ 
in 2030. The Netherlands has not included a specific target on the renewable energy share in 
buildings.  The  plan  merely  refers  to  projections  within  the  range  of  41-49%  for  2030.  The 
Netherlands does not confirm the binding targets in heating and cooling for both 2021-2025 
and  2026-2030  periods  and  does  not  include  an  indicative  target  to  achieve  the  top-ups  of 
Annex IA of the revised RED II.  

The  Netherlands  has  partially  addressed  recommendation  7.  The  Netherlands  present 
detailed and quantified policies and measures to meet the Dutch contribution to the 2030 EU 
renewable energy target of 32-42% based on WAM scenario. The Netherlands describes how 
it plans to accelerate permitting (notably with the Environmental Act) and as regards green gas 
and  energy  infrastructures,  by  covering  different  levels  of  administration  (at  national, 
provincial and municipal levels) as well as how it will design the obligation on fuel suppliers 
in  the  transport  sector.  However,  the  Netherlands  does  not  indicate  the  renewable  energy 
technologies  for  which it  plans to  designate  ‘renewables  acceleration areas’ with  faster  and 
simpler procedures. 

The  Netherlands  has  partially  addressed  recommendation  8.  The  final  NECP  outlines 
where projections on bioenergy demand and supply per sector, and data for imports and the 
source of forest biomass used for energy can be found. It also indicates that an assessment of 
the  compatibility  of  the  projected  use  of  forest  biomass  for  energy  production  with  the 
Netherlands’ obligations under the revised LULUCF Regulation, particularly for 2026-2030, 
will be included in the Dutch Bioraw Materials Strategy currently being preprared. Finally, the 
Netherlands 
the  sustainable  production  of 
biogas/biomethane, digestate and biogenic CO2. 

includes  further  measures 

to  promote 

The Netherlands has not addressed recommendation 9, as it does not provide an expected 
timeline  and  the  procedural  steps  leading  to  the  adoption  of  legislative  and  non-legislative 
policies and measures  aimed at  transposing  and implementing  the provisions  of the revised 
RED II. 

197 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  

173 

 
 
 
 
 
 
2.3  ENERGY EFFICIENCY DIMENSION 

The Netherlands has partially addressed recommendation 10. The Netherlands included an 
indicative national contribution of 38.4 Mtoe to the Union’s binding final energy consumption 
target for 2030. This contribution is in line with Article 4 of Directive (EU) 2023/1791 (‘EED 
recast’)198. 

The Netherlands did not include the amount of energy consumption reduction per year to be 
achieved by all public bodies. The Netherlands reported the total floor area of 2,160,000 m2 of 
heated and cooled buildings owned by public bodies to be renovated yearly and it also specified 
that it opted for the default approach. The Netherlands set out policies and measures to achieve 
the renovation of public buildings. The Netherlands included the amount of cumulative energy 
savings of 30.7 Mtoe to be achieved over the period from 1 January 2021 to 31 December 2030 
and included an explanation on how the annual savings rate and the calculation baseline were 
established. 

The  Netherlands  has  partially  addressed  recommendation  11.  The  Netherlands  set  out 
complete policies and measures to achieve the required amount of cumulative end-use energy 
savings  by  2030  and  it  quantified  the  energy  savings  from  the  reported  energy  efficiency 
measures to ensure the achievement of the cumulative target. Furthermore, the Netherlands set 
out adequate measures to promote energy audits and energy management systems and specified 
robust  energy  efficiency  financing  programmes  and  support  schemes,  including  financial 
instruments  and  public  guarantees,  able  to  mobilise  private  investments  and  additional  co-
financing. The Netherlands specified existing policy measures to promote the uptake of energy 
efficiency lending products and innovative financing schemes (such as third-party financing).  

The Netherlands has partially addressed recommendation 12. The Netherlands included an 
updated ambition level to ensure a highly energy efficient and decarbonised national building 
stock and to transform existing buildings into zero-emission buildings by 2050. The new 2030 
target is 13.2 MtCO2-eq which is about 14% lower than the initial target set in the 2020 long-
term renovation strategy (LTRS). The Netherlands did not include energy savings milestones 
for the buildings stock and did not detail the impact in terms of energy savings of each new 
measure put forward. 

2.4  ENERGY SECURITY DIMENSION 

The Netherlands partially addressed recommendation 13. The final updated plan neither 
defines clear objectives in terms of diversification of energy sources, nor does it describe the 
measures taken to assess the compatibility of national gas infrastructure with decarbonisation, 
nor further explain how the Netherlands intends to further encourage gas demand reduction. 
However,  the  annex  of  the  plan  provides  a  forecast  for  the  evolution  of  gross  inland  gas 
consumption which should decrease from 31 438 ktoe in 2020 to 20 389 ktoe in 2030 and 18 
239 in 2040 and of domestic natural gas production which should decrease from 17 261 ktoe 
in 2020 to 5 975 ktoe in 2030 and 2 913 ktoe in 2040.  

198 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 

174 

 
 
 
 
 
 
The final plan does not add additional information on energy storage deployment.  

The final plan indicates ongoing assessments of risks of climate change to the energy network 
and the measures to be taken. More concrete targets will be developed in 2026.       

The final plan includes forecasts on oil consumption until 2050 and a rough assessment of the 
adequacy of the oil infrastructure in the long run (refineries, pipeline, oil stocks) considering 
the expected oil demand decline and the move to lower-carbon alternatives.  

On nuclear, the plan and its annexes provide information on plans to  exploit and extend its 
existing  uranium  enrichment  facilities.  It  also  provides  information  on  the  Netherlands’ 
ambition to extend the lifetime of the Borssele nuclear power plant and possibly to construct 
two  new  additional  reactors.  However,  the  plan  indicates  that  this  policy  direction  may  be 
changed based on the Framework Coalition Agreement 2024–2028. 

The final NECP includes nuclear fuel diversification measures. It clarifies that the economic 
entities  operating  the  existing  fuel  cycle  facilities,  in  particular  for  isotope  enrichment,  are 
responsible for diversifying their spare parts and services. Due to the strong market position of 
these entities, no additional governmental strategy is deemed to be needed. The operator of the 
Borssele nuclear power plant is reported to no longer have direct business with Russia. On the 
long-term management of radioactive waste, the plan refers to the National Programme for the 
management of radioactive waste and spent fuel. The NECP indicates that an update of the 
Programme will be published in 2026. 

2.5  INTERNAL ENERGY MARKET DIMENSION 

The Netherlands has partially addressed recommendation 14. The plan refers to the EU 
Electricity Market Design Package, as well as the ‘Nationaal Plan Energiesysteem’ (NPE) of 
2023, in which flexibility of the electricity system is recognised as an important focus area. 
The Netherlands explains that the development  of flexibility  will be further monitored, and 
further government intervention considered if needed. It does not, however, define clear targets 
or elaborate on criteria that will be followed in the monitoring exercise. Even though the final 
NECP provides a good overview of measures aimed at facilitating energy system integration, 
it  does  not  provide  information  on  specific  measures  to  facilitate  system  integration  of 
renewable electricity in accordance with Article 20a of the revised RED II. The newly adopted 
Energy  Law  contains  several  provisions  aimed  at  strengthening  the  position  and  choice  of 
energy consumers, including giving energy communities an official legal status and a separate 
role in the energy market.   

The Netherlands has partially addressed recommendation 15. The plan lists the work done 
so far to address energy poverty and gives a good overview of the measures currently in place, 
particularly on the work together with local authorities in the 3-year National Energy Poverty 
Research Programme and on making use of local ‘energy fixers’ teams. Furthermore, measures 
are included to support vulnerable households in making their homes more energy efficient and 
gas free.  Currently the more structural measures focus on energy efficiency, and a strategic 
workplan  is  being  developed.  The  plan  describes  well  all  the  ongoing  reflections  by  TNO 
(independent research company employed by the government) to research energy poverty and 
to  draw  an  energy  poverty  definition  for  use  in  policy  making.  Four  indicators  have  been 

175 

 
 
 
 
 
 
designated to be used when researching energy poverty.  However, a target for reducing the 
number of households in energy poverty is still missing. 

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

The Netherlands has partially addressed recommendation 16. The plan includes national 
objectives  in  research,  innovation  and  competitiveness  to  deploy  clean  technologies.  It 
mentions a general target of 3% GDP spending on R&I (not energy specific) and establishing 
a pathway for 2030. The NECP lists national funding schemes and provides an overview by 
sectors of expenditure for 2022-2028 related to climate policy, and related subsidies for certain 
technologies.  The  National  Growth  Fund  has  been  established  to  support  knowledge  and 
innovation (not energy specific). Certain long-term policies on decarbonisation are mentioned 
as pathway towards 2050 to support industry and promote the transition of businesses towards 
a net zero and circular economy.  

Significant  policies  and  measures  include  the  development  of  hydrogen  infrastructure  and 
production,  additional  capacity  for  nuclear  energy  and  offshore  wind  parks  in  the 
Supplementary Roadmap Windenergie 2030. The plan puts forward policies and measures to 
promote the development of net-zero projects, including those relevant for energy intensive 
industries. It refers to the regulatory framework for permitting procedures (Environment Act). 

The  plan  provides  policies  and  measures  for  the  digitalisation  of  the  energy  system,  the 
development of clean energy-related skills (the Human Capital Agenda) such as labour-saving 
innovation or innovation on energy transition, and to facilitate open trade  

The plan includes projects to develop resilient and sustainable supply chains for key net-zero 
components and equipment, in the field of solar PVs (SolarNL), circular batteries and polymer 
materials. 

The  circular  economy  is  well  integrated  throughout  the  plan.  Its  GHG  emissions  reduction 
potential is quantified, and it is underlined as a key component of the transition, with several 
policies and measures described in detail.      

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

The Netherlands partially addressed recommendation 17. While the plan does not provide 
a detailed estimate of the investment needs, it outlines the planned public expenditure to finance 
climate  policies  by  sector  for  the  period  2022-2028.  The  plan  does  not  provide  a  detailed 
assessment  on  how  public  investments  will  mobilise  private  investments.  However,  it  does 
describe  public-private  programmes  focussing  specifically  on  the  green  transition.  It  also 
outlines incentives, such as subsidies, energy taxation, and risk mitigation measures, that will 
encourage  private  sector  investment  in  the  climate  and  clean  energy  transitions.  The 
information provided in the plan is not sufficient to assess a potential financing gap with respect 
to the investment needs, or how this would be filled. 

The Netherlands has not addressed the recommendation to provide a robust assessment 
of  the  macroeconomic  impact  of  the  planned  policies  and  measures.  The  plan  does  not 
include quantitative estimates of its impact on GDP, employment and government revenues. 

176 

 
 
 
 
 
2.8  JUST TRANSITION 

The  Netherlands  has  partially  addressed  recommendation  20.  The  plan  provides 
information  on  the  impact  of  the  transition  to  climate  neutrality  on  employment  and  skills. 
However,  it  lacks  a  more  detailed  mapping  of  the  social  and  employment  impacts  of  the 
transition on specific groups and does not address labour shortages due to skill mismatches. 
Nonetheless,  the  plan  specifies  how  the  Green  and  Digital  jobs  action  plan  will  stimulate 
education in STEM sectors and life-long learning.  

The plan refers to the natural gas phase-out as a just transition element, and explains how the 
Just Transition Fund (JTF) will counter negative socio-economic impacts of the transition in 
selected areas by addressing energy poverty, stimulating up and re-skilling, innovation and job 
creationThe plan provides the first elements of the analytical basis needed for the preparation 
of the Social Climate Plan, providing estimates of the aggregate effect of ETS2 on households 
and transport users costs. It provides broad categories of households and transport users that 
are  most  likely  to  be  affected  by  ETS2.  However,  it  lacks  a  more  granular  and  detailed 
assessment of the effects of ETS2 and the subsequent identification of vulnerable groups. The 
plan does not explain how the policy framework identified in the NECP will contribute to the 
preparation of the Netherlands’ Social Climate Plan nor how the consistency of the plans will 
be ensured.  

2.9  PUBLIC CONSULTATION 

The  Netherlands  has  addressed  recommendation  21.  The  Netherlands  organised  several 
rounds of consultation. The first, on the draft NECP run from July 2023 to October 2023. An 
online  public  consultation  on  the  draft  updated  NECP  took  place  for  six  weeks  between  1 
December  2023  and  12  January  2024.  The  plan  describes  the  National  Citizens’  Forum  on 
Climate Policy established in July 2023, and the public campaign “Save the button” launched 
that  August,  organised  to  involve  citizens  at  national  level.  The  plan  provides  a  link  to  a 
consultation report that gives an overview of the main results and explains how the different 
views were incorporated into the plan. 

2.10 REGIONAL COOPERATION 

The Netherlands has partially addressed recommendation 22. The plan includes a list of 
initiatives aiming at increasing the Netherlands’ engagement with neighbouring Member States 
(notably the regional cooperation in the Pentalateral Forum (NL, BE, LU, DE, FR, AT)) and 
within the context of the Energy Cooperation between the North Seas Countries, where detailed 
information  on  regional  cooperation  is  provided.  The  plan  does  not  yet  identify  common 
challenges and shared objectives in terms of interconnectivity, renewables, energy efficiency 
and internal market in a detailed way.  

The Netherlands does not provide additional information on establishing the  framework for 
cooperation on joint projects by 2025 in line with Article 9 of the revised RED II. Regarding 
the signature of three bilateral solidarity arrangements for the security of gas supply with its 
neighbours (Ireland, Belgium, Germany), the final plan highlights the necessity to assess the 

177 

 
 
 
 
 
need  for  such  agreements  in  light  of  the  recent  addition  of  default  solidarity  provisions  to 
Regulation (EU) 2017/1938 but does not mention any progress or new efforts to be undertaken. 

2.11 ANALYTICAL BASIS 

The plan describes  the analytical  framework  and includes projections  until 2050. It  embeds 
economic, social, employment and skills impacts.  

The methodologies used are described in detail for the WEM (“KEV 2022) and WAM (“KEV 
2023”) scenarios. For these, the NECP provides an impact assessment of policies and measures, 
but it lacks an assessment of new policies, foreseen for March 2025. 

The  plan  does  not  include  quantitative  estimates  of  impacts  on  GDP,  employment  and 
government revenue. 

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

The Netherlands has addressed recommendation 18. The plan sufficiently covers the main 
reforms  and  investments  of  the  Recovery  and  Resilience  Plan  (RRP)  that  contribute  to 
implementing the objectives, targets and contributions of the Energy Union. However, some 
investments and reforms have not been adequately recognized as part of the RRP, such as the 
energy taxation reform and the CO2 levy for industry.   

3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

The Commission encourages the Netherlands to ensure a timely and complete implementation 
of the measures needed to achieve its national climate and energy targets. The Netherlands is 
invited to pay particular attention to the following main elements:  

•  Closely monitor the impacts of policies on greenhouse gas emission reductions, to meet 
the ESR target. Implement additional measures coordinating efforts across all economic 
sectors in line with nationally set decarbonisation objectives for 2030. 

•  Promote  sustainable  land  use,  including  by  encouraging  sustainable  agriculture 

practices. 

•  On adaptation, assess future water demand under different climate scenarios and evaluate 
impacts on the energy system, paying attention to possible cross-sectoral water conflicts. 
Carry  out  a  comprehensive  vulnerability  assessment  of  the  energy  network  and 
infrastructure based on different climate scenarios. This would enable identifying potential 
weaknesses of the energy sector and develop measures to address them. 

•  Clarify  existing  fossil  fuel  subsidies  and  provide  a  detailed  timeline  for  their  gradual 

phase-out. 

•  As regards renewable energy, put in place measures to achieve at least the 39% share for 
renewables  by  2030  that  aligns  with  the  EU’s  collective  target  for  renewable  energy. 
Develop  a  more  comprehensive  plan  to  increase  the  use  of  renewables  in  heating  and 
cooling and identify specific technologies to be covered by the renewables acceleration 
areas, subject to the new permitting rules of the revised RED II.  

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•  Further address network congestion, as it is a major obstacle to the transition to a higher 
share  of  renewable  energy  and  decarbonisation  efforts. This  is  particularly  relevant  for 
industrial sectors, which are major energy consumers and face long waiting times for grid 
connections. 

•  On  energy  efficiency,  strengthen  existing,  or  implement  additional,  energy  efficiency 
policies and measures to ensure it will meet its 2030 national contribution for FEC. 
•  On buildings, ensure the timely implementation of the main measures in the Long-Term 
Renovation  Strategy  such  as  renovating  the  worst-performing  rented  dwellings, 
commercial properties, and offices to increase renovation rates. 

•  On  industry,  put  in  place  robust  measures  on  decarbonisation,  and  accelerate  the 
‘maatwerkaanpakken’  (a  tailored  approach  to  reducing  emissions),  develop  and  deploy 
relevant clean technologies at scale, further integrate the 'energy efficiency first' principle 
and address structural congestion to ensure efficient market access. 

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Austria 

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Austria’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for 
additional net GHG 
removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 

Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

National contribution for 
energy efficiency: 

2022: -19% 
2023: -23.3%199 

-48% 

2022: Reported 
net removals of 
–5.84 Mt CO2 
eq.  

-0.88 Mt CO2 
eq. (additional 
removal 
target) 

36.55% 
(SHARES) 
34% 
(target) 

2023: 40.84% 

At least 57% 

Primary energy 
consumption  

31.5 Mtoe 

2023: 29.35 
Mtoe 

25.92 Mtoe 

NECP:  
-41.7 up to -46% 
However, AT is 
expected to meet 
the 2030 target 
with ESR 
flexibilities  

An 
overachievement 
of -3.36 Mt CO2 
eq compared to 
the 2030 target 

Austria’s 
contribution of at 
least 57% is in 
line with the level 
required under the 
formula set out in 
Annex II to the 
Governance 
Regulation200. 

AT primary 
energy 
consumption 
contribution of 
25.92 Mtoe is not 
in line with the 
EED recast Annex 
I formula results: 
24.9 Mtoe 
(Reference 

199  The ESR emissions in 2022 are based on 2024 final GHG inventory reports, and 2023 emissions are based on 
2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as set out 
in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions for 2021-
2025 will only be established in 2027 after a comprehensive review. 
200 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’).  

180 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Final energy consumption 

25.1 Mtoe 

2023: 24.17 
Mtoe 

21.59 Mtoe 

Level of electricity 
interconnectivity (%)201 

37.6% 

2024: 29.0% 

15% 

Source: Eurostat; Austria’s final updated national energy and climate plan 

Scenario) or 24.0 
Mtoe (Updated 
Reference Scenario 

AT final energy 
consumption 
contribution of 
21.59 Mtoe is in 
line with the 
national 
contribution of 
21.61 Mtoe 
submitted by the 
Commission. 

Austria surpasses 
the EU-wide 
interconnectivity 
target. 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In October 2024, the Commission published a thorough assessment of Austria’s draft updated 
NECP  and  provided  recommendations 202  for  the  preparation  of  the  final  updated  NECP.  
Austria submitted its final updated NECP on 18 December 2024, almost six months after the 
deadline of 30 June 2024.203 

2.1  DECARBONISATION 

Austria  expects  to  decrease  total  net  GHG  emissions  (including  LULUCF  and  excluding 
international aviation) by 28% in 2030, 52% in 2040 and 67% in 2050, as compared to 1990. 
The  final  updated  plan  reconfirms  the  Federal  Government’s  commitment  to  reach  climate 
neutrality by 2040 for sectors not covered by the EU ETS. 

2.1.1  Effort Sharing Regulation 
Austria  has  partially  addressed  recommendation  1.  The  final  NECP  provides  sufficient 
details on how Austria will meet its ESR target of -48% by 2030 compared to 2005. 

The  plan  presents  the  same  projections  as  in  the  draft  plan,  showing  that  the  existing  and 
planned policies and measures will lead to a decrease of 41.7% in 2030 compared to 2005, a 
gap of 6.3 percentage points compared to the national ESR target. However, the plan estimates 
that additional measures, including the implementation of CCS projects and the elimination of 
fossil fuel subsidies, which are not included in the projections, will further reduce emissions, 
achieving  a  total  of  -46%.  Moreover,  the  use  of  ETS  flexibilities  is  expected  to  bridge  the 
remaining  2  percentage  point  gap  to  target.  In  2023,  GHG  emissions  from  ESR  sectors 

201  Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2024). The 2030 level 
represents the general interconnectivity target of 15%. 
202  SWD(2024)  850 final, and Commission Recommendation of 18 October 2024, C/2024/8100. 
203 Article 14(2) of Governance Regulation. 

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represented 64% of Austria’s total emissions (61% in 2030)204, with transport accounting for 
the largest share. The ‘with additional measures’ (WAM) projected value for ESR in 2030 is 
approximately  17%  lower  than  the  ‘with  existing  measures’  (WEM)  scenario,  indicating  a 
significant  gap  between  the  two,  especially  considering  that  the  WAM  projections  do  not 
include all planned measure. This highlights the importance of fully implementing all existing 
and planned policies and measures, as well as further additional measures, to reach the target. 

The plan covers all ESR sectors comprehensively, though it does not include further details 
on the policies and measures, their scope, timeline and expected impact on GHG emissions as 
compared to the draft. 

Transport emissions are expected to fall more rapidly, with the WAM projections showing an 
annual percentage decrease of 8.2% in 2022-2030, more than double the -3.9% rate seen in 
2015-2022.205 To reach this desired level, an additional decrease of 2.4 Mt CO2eq is needed 
compared to the WEM. Full implementation of all policies and measures is therefore crucial to 
achieve this goal. 

On agriculture, the plan provides sufficient detail in terms of funding and impacts of policies 
and measures, and how these contribute to the ESR target. The projections indicate a reduction 
in emissions by 16.7% under WAM and 8.3% under WEM in 2030 compared to 2005, which, 
although slow, represents a decrease. 

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings,  road  transport  and  additional  sectors  (ETS2).  The  WAM  scenario  projections 
account for the effect of ETS2, however they do not clearly consider the impact of ETS2 in 
achieving the ESR target. 

2.1.2  LULUCF 
Austria  has  partially  addressed  recommendation  3.  The  LULUCF  sector  in  Austria 
generates  net  removals,  absorbing  roughly  6.1%  of  the  total  GHG  emissions  in  2022. 
According to the LULUCF Regulation, Austria has to increase its net removals by -0.879 Mt 
CO2eq in 2030 as compared to its yearly average in the 2016-2018 reference period. Despite a 
declining trend in its carbon sink, projections for 2030 show that Austria will overachieve its 
target by -3.36 Mt CO2eq. 

The plan indicates that for LULUCF there are no additional policies compared to the baseline 
scenario. However,  it  acknowledges  the  importance  of  carbon  farming  measures  whose 
potential will be assessed by 2026. Concerning projections, the plan does not provide specific 
quantifications  of  how  policies  contribute  to  achieving  the  target.  Furthermore,  it  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. 

2.1.3  Carbon Capture and Storage 
Austria has partially addressed recommendation 2. The plan highlights the importance of 
CCUS  and  outlines  the  main  components  of  Austria’s  Carbon  Management  Strategy.  It 

204 Total GHG excluding LULUCF. Source: Commission calculations based on the Austrian final updated NECP  
205 Compound annual growth rate based on the ESR share of transport, sourced from EEA, whose data is aligned 
with data included in the NECP.  

182 

 
 
 
 
 
 
includes a reference that 0.5MtCO2 can be captured by 2030 to contribute to the ESR target, 
but without including the source.  

2.1.4  Adaptation 
Austria  has  partially  addressed  the  recommendation  4.  The  plan  refers  to  the  Austrian 
Strategy  for  Adaptation  to  Climate  Change  (NAS),  acknowledging  the  importance  of 
integrating adaptation planning. It is also already very comprehensive and embeds adaptation 
policies  and  measures  in  the  relevant  Energy  Union  dimensions.  However,  as  quantitative 
measurements of adaptation needs and policies are currently hardly available, these links 
are established in a qualitative way.  

The plan partially outlines the link to the specific Energy Union objectives and policies that 
adaptation policies and measures are meant to support. It includes numerous references to the 
NAS and its Action Plan (NAP), which address climate adaptation needs and measures in the 
energy  sector.  It  also  refers  to  the  relevant  provisions  of  the  Austrian  Integrated  Network 
Infrastructure Plan (ÖNIP). 

2.1.5  Fossil Fuels 
Austria  has  partially  addressed  recommendation  21.  The  plan  includes  the  objective  to 
reduce 2MtCO2eq by 2030 through the phase out of fossil fuel subsidies. It indicates the work 
so far done for analysing and reporting such subsides, while the concrete way and timing of 
the phase-out is tasked to the Federal Ministry of Finance, which will set up an inter-ministerial 
working group to ensure that the reduction target is met.  

2.2  RENEWABLES  

Austria  has  partially  addressed  recommendation  5.  Estimated  trajectories  for  renewable 
energy  technologies  are  included  up  to  2030,  but  not  beyond  and  for  the  electricity  sector 
provided  for  2040.  The  updated  plan  does  not  contain  the  target  on  innovative  renewable 
energy  technologies  to  contribute  to  the  indicative  5%  target  in  line  with  Directive  (EU) 
2018/2001 (the ‘revised RED II’)206. The plan does not include specific targets to achieve the 
indicative sub-targets in buildings, transport and industry for 2030. The plan does not contain 
the specific target for RFNBOs of hydrogen use in industry by 2030, but it includes a target of 
1 GW of installed electrolyser capacity by 2030. Austria plans, to introduce requirements for 
the  use  of  renewables  in  transport  in  line  with  the  legal  requirements  as  well  as  renewable 
hydrogen in industry. The plan includes measures for district heating and cooling but does 
not provide a target.  

Austria  has  partially  addressed  recommendation  6.  Austria  plans  to  implement  the 
provisions on permit-granting of the revised RED II as amended through a renewable energy 
acceleration law and through measures at the level of the federal states for the implementation 
of renewables acceleration areas (with a focus on wind and solar PVs), but the final plan does 
not provide further detail on this. The final NECP announces measures to promote the uptake 
of PPAs, without going into further detail. The enabling framework for energy communities 

206 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413.  

183 

 
 
 
 
 
 
is deemed effective, as more than 1000 energy communities are active in Austria. The final 
NECP describes measures to promote hydrogen use in the industry sector but does not explain 
how  Austria  prepares  for  renewable  hydrogen  trade.  Further,  the  NECP  sets  out  that  the 
provisions on promoting renewables in transport, which include the obligation on fuel suppliers 
will be implemented in the form of a multi-modal fuel act.  

Austria  has  not  addressed  recommendation  7.  The  final  NECP  does  not  include  a  full 
assessment  of  the  domestic  supply  of  forest  biomass  for  energy  purposes  in  2021-2030  in 
accordance with the strengthened sustainability criteria of the revised RED II as amended nor 
does it include an assessment of the compatibility of the projected use of forest biomass for 
energy  production  with  Austria’s  obligations  under  the  revised  LULUCF  Regulation, 
particularly  for  2026-2030,  together  with  national  measures  and  policies  to  ensure  such 
compatibility. In addition, Austria did not provide projections for biomass supply by feedstocks 
and origin and explained that it was not possible to differentiate between raw materials and 
sources of supply for biomass. Also, the final NECP does not include any data on imports. As 
for biomethane, Austria has addressed all recommendations to support sustainable biogas and 
biomethane production.  

Austria  has  not  addressed  recommendation  8.  The  plant  does  not  provide  an  expected 
timeline  and  the  procedural  steps  leading  to  the  adoption  of  legislative  and  non-legislative 
policies and measures  aimed at  transposing  and implementing  the provisions of  the revised 
RED II. 

2.3  ENERGY EFFICIENCY DIMENSION  

Austria has partially addressed recommendation 9. Austria included an indicative national 
contribution of 21.6 Mtoe to the Union’s binding final energy consumption target for 2030207. 
This contribution is in line with Article 4 of Directive (EU) 2023/1791 (‘EED recast’)208, or 
equal  to  the  corrected  indicative  national  contribution  that  the  Commission  submitted  to 
Austria in March 2024 under Article 4(5) of that Directive.  

Austria  includes  an  indicative  national  contribution  of  25.9  Mtoe  to  the  Union’s  indicative 
primary energy consumption target for 2030. This contribution is not in line with Article 4 of 
EED Recast. There is still a gap of 4.2% compared to the target calculated with respect to the 
indicative results of the 2020 reference scenario, and a gap of 8.0% compared to the target 
calculated with respect to the indicative results of the updated 2020 reference scenario. 

Austria  has  partially  addressed  recommendation  10.  The  plan  includes  the  amount  of 
energy consumption reduction of 8 ktoe per year disaggregated by sector to be achieved by all 
public bodies with more than 50.000 inhabitants209. Austria does not report the energy savings 

207  The  target  currently  in  force  is  equal  to  21.97  Mtoe,  corresponding  to  gaps  of  1.7%  to  the  corrected 
contribution, 2.9% to the EU Reference Scenario and 8.8% to the updated EU Reference Scenario. The target of 
21.59 Mtoe is the one to be considered when EED will be transposed to the national legislation. WAM projections 
are also mentioned, equal to 24.6 Mtoe. 
208 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 
209 As required by Article 5 of EED Recast. 

184 

 
 
 
 
 
 
to be achieved by all public bodies210 but it specified that it opted for a combined approach211. 
Austria sets out policies and measures to achieve the reduction of energy consumption from 
public  bodies  and  will  apply  for  instance  on  thermal  renovations,  energy  management  and 
trainings for building users on energy-efficient behaviour and conscious use of resources. 

Austria  has  addressed  recommendation  11.  Austria  includes  the  amount  of  cumulative 
energy  savings  of  17.13  Mtoe  to  be  achieved  over  the  period  from  1  January  2021  to  31 
December 2030 in line with Article 8 of EED Recast and included an explanation on how the 
annual savings rate and the calculation baseline were established.   

Austria has addressed recommendation 12. Austria sets out complete policies and measures 
to  achieve  the  national  contributions  on  energy  efficiency  including  measures  to  promote 
energy  audits  and  energy  management  systems.  The  main  measures  are  investments  in  the 
thermal  renovation  of  buildings,  energy  management  systems  in  buildings,  the  use  of 
commercial and industrial waste heat and support for e-mobility.  

Austria specifies how the energy efficiency first principle will be implemented and mentioned 
energy efficiency measures such as energy renovation of buildings and mobility to implement 
the principle. 

Austria  has  not  addressed  recommendation  13.  The  plan  does  not  include  an  updated 
ambition level to ensure a highly energy efficient and decarbonised national building stock and 
to  transform  existing  buildings  into  zero-emission  buildings  by  2050.  Austria  included 
intermediate milestones for 2030 and intermediate milestones for 2040 but only related to GHG 
emissions and not to energy savings. Austria detailed the impact in terms of energy savings 
under Art.8 of each new measures put forward. 

2.4  ENERGY SECURITY DIMENSION 

Austria has not addressed recommendation 14. The final NECP does not set out a roadmap 
for securing alternative supplies to Russian gas nor explain how Austria will further encourage 
gas demand reduction. It also does not provide quantified long-term gas consumption forecasts 
beyond noting that a decrease is foreseen. 

Austria has partially addressed recommendation 15. The final plan includes measures to 
improve  the  flexibility  of  the  system.  It  provides  little  new  information  on  integrating  the 
imperative of climate change compared to the draft plan, yet it clarifies the link to Austria’s 
national  adaptation  strategy,  which  includes  a  detailed  vulnerability  assessment  and  a 
comprehensive list of recommended actions in the various components of the energy system.  

Austria  has  partially  addressed  recommendation  16.  The  plan  includes  measures  to 
decrease oil import dependency and long-term projections of oil consumption. However, the 

210 Austria specified that this area is going to change due to the EED III implementation and the expansion of the 
obligation to the whole building stock. The energy savings target, derived from the 3% renovation rate of buildings 
owned by public bodies, has been re-introduced for the Federal Government for the period 2025 to 2030. Länder, 
cities and municipalities, are not covered in the value presented. 
211 Annex including the responses of Austria to the recommendations mentions that "The vast majority of local 
and regional authorities have opted for the alternative approach." 

185 

 
 
 
 
 
 
 
plan does not assess the adequacy of the oil infrastructure (refineries, pipelines, oil stocks) in 
the long run with the expected oil demand decline and the move to lower-carbon alternatives. 

2.5  INTERNAL ENERGY MARKET DIMENSION 

Austria has partially addressed recommendation 17. The final plan does not detail specific 
means  to  promote  non-fossil  flexibility  such  as  demand  response  and  storage  nor  defines 
quantitative flexibility needs. Austria intends to complete the legal framework for flexibility 
resources by means of the draft Electricity Industry Act (EIWG) that has not yet been adopted. 
The  act  will  specify  (independent)  aggregation  and  enable  full  participation  of  demand 
response at storage at wholesale electricity markets. The procurement of flexibility by system 
operators for system services shall be facilitated by the implementation of a flexibility platform. 
In  parallel,  implicit  demand  response,  as  ‘grid-friendly’  behaviour  of  consumers  shall  be 
incentivised via time of use tariffs and dynamic retail tariffs.  

Austria does not describe the specific measures to facilitate system integration of renewable 
energy in accordance with Article 20a of the revised RED II. 

Austria acknowledges the importance of consumer empowerment and protection measures to 
prevent climate action from endangering the affordability of housing and energy and to ensure 
consumers’ trust in energy markets but does not set out specific measures or actions towards 
achieving more empowerment.  

Austria  has  partially  addressed  recommendation  18.  The  NECP  presents  quantified 
information on energy poverty, relying on several indicators, and highlights several concrete 
measures and programmes to alleviate it, but lacks quantifiable targets. Austria stipulates that 
the Energy Poverty Definition Act is in political negotiations and is intended to provide the 
legal  basis  for  the  statistical  recording  and  monitoring  of  energy  poverty;  the  2023  Energy 
Efficiency Act established the Coordination Body for Combating Energy Poverty (KEA) as the 
central contact and competence centre for energy poverty in Austria and a data and monitoring 
plan on energy poverty is being drawn up to help develop a concrete, measurable reduction 
target. Austria furthermore highlights its short-term and ongoing measures to alleviate energy 
poverty, with energy cost subsidies, a Housing Energy programme, income support, housing 
benefits and energy advice to reduce energy consumption.  

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Austria has partially addressed recommendation 19. The plan includes a comprehensive 
approach,  although  it  does  not  include  specific  targets  to  support  research,  innovation  and 
competitiveness in all relevant clean energy technologies, establishing a pathway to 2030 and 
2050. The plan included measures to promote the development of net-zero projects including 
those relevant for the energy intensive industries. Flagship projects promote a wide range of 
research  and  innovation,  from  renewable  energy  technologies  to  energy  efficiency  and 
sustainable  mobility.  The  chapter  did  not  fully  describe  how  the  measures  will  ensure  a 
predictable and simplified regulatory framework for permitting procedures for manufacturing 
or  how  access  to  national  funding  will  be  simplified  where  needed.  The  plan  included 
information on policies and measures for the development of clean energy-related skills and 
facilitate resilient and sustainable supply chains of key net-zero components and equipment.  

186 

 
 
 
 
 
 
2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Austria  has  partially  addressed  recommendation  20.  The  plan  provides  estimates  of  the 
investment needs for key sectors, but not at the level of the planned measures. It provides a 
detailed overview of the available public budget per sector and describes the initiatives and 
measures to mobilise private investments. The assessment is based on a sound methodology, 
using a top-down model. 

The information provided in the plan is not sufficient to estimate whether there is a potential 
financing gap with respect to the investment needs, or how this would be filled. 

Austria  has  addressed  the  need  to  provide  a  robust  assessment  of  the  macroeconomic 
impact of the planned policies and measures on value-added,  consumption, employment, 
and investment. The methodology employed is outlined in the referenced documents. 

2.8  JUST TRANSITION 

Austria has partially addressed recommendation 22. The plan provides information on the 
impact of the transition to climate neutrality on employment and skills but does not sufficiently 
address the impact on the most vulnerable households. Moreover, the plan does not specify the 
form  of  support,  the  impact  of  initiatives  or  the  resources  available,  except  for  the  Just 
Transition Fund (JTF).  

Regarding the Social Climate Fund, despite the above-mentioned reference, the plan lacks the 
analytical basis needed for the preparation of the Social Climate Plan, such as information on 
the estimated impact of ETS2 and the identification of vulnerable groups. The plan does not 
explain how the policy framework identified in the NECP will contribute to the preparation of 
Austria’s Social Climate Plan nor how the consistency of the two plans will be ensured.   

2.9  PUBLIC CONSULTATION 

Austria  has  not  addressed  recommendation  23.  Austria  provides  very  little  information 
about the public consultation on the draft and final NECP. The plan indicates that consultation 
with the key stakeholders and social partners (economic camera, Chamber of Labour, Chamber 
of Agriculture, Austrian Trade Union Confederation) was done through the National Climate 
Change  Committee  and  also  involved  the  Citizens’  Climate  Council.  The  plan  does  not 
describe how it was carried out, (e.g. the consultation period) nor provides a summary of the 
outcome of the consultation nor how the views were considered. 

2.10  REGIONAL COOPERATION 

Austria  has  not  addressed  recommendation  24.  The  plan  does  not  make  a  reference  to 
having engaged in regional cooperation, notably the Central and South-Eastern Europe Energy 
Connectivity (CESEC) High-Level Group. Moreover, it does not describe how Austria plans 
to establish a framework for cooperation with other Member States by 2025, in line with Article 
9 of the revised RED II. The final plan does not refer to any efforts nor progress regarding the 
signature of the remaining bilateral solidarity agreements with Austria’s neighbours (Hungary, 
Slovakia, Czechia, Slovenia). 

187 

 
 
 
 
 
2.11  ANALYTICAL BASIS 

The methodologies and models used for the analytical basis of the NECP, are described in a 
separate document by the Austrian Federal Environmental Agency (UBA)212. The draft NECP 
provides an impact assessment of policies and measures, which includes a partial assessment 
of economic, employment, social, and health impacts.  

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

The Austrian final updated NECP covers sufficiently the main reforms and investments of the 
Recovery and Resilience Plan (RRP) that contribute to implementing the objectives, targets, 
and contributions.   

3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

Austria needs to  swiftly  proceed with  implementing its final  integrated national  energy and 
climate plan. Austria is invited to pay particular attention to the following main elements:   

•  On ESR, implement in a timely manner the identified additional policies to meet the 2030 
target  (including  reducing  fossil  fuel  subsidies  and  deployment  of  Carbon  Capture  and 
Storage). While Austria is expected to achieve its ESR target with the use of flexibilities, 
part of the emissions reduction is driven by measures that are not yet fully in place.   
•  On  LULUCF,  implement  continuous  monitoring  and  address  the  long-term  declining 

trend in the carbon sink.  

•  On  adaptation,  assess  quantitatively  relevant  climate  vulnerabilities  and  risks  for  the 
national objectives, targets, and contributions and the policies and measures in the different 
Energy Union dimensions. That would enable better outlining and quantifying the link to 
the specific Energy Union objectives and policies, that adaptation policies and measures 
are meant to support. 

•  Continue the commitment to phase out the fossil fuel subsidies identified in the NECP by 
2030. Clarify existing fossil fuel subsidies along with a detailed timeline for their gradual 
phase-out. 

•  On  transport,  fully  implement  the  2030  Mobility  Master  Plan,  and  use  strategically 
funding instruments to incentivise the electrification of the vehicle fleet, the expansion of 
related infrastructure, and the promotion of public transport. 

•  On  buildings,  promote  thermal  renovation,  renewable  energy  deployment,  and  heating 
system upgrades, among others through funding instruments and regulatory measures, and 
provide a stable and predictable framework. Accelerate the pace and depth of renovations 
by  increasing  the  availability  of  technical  assistance  facilities  and  one-stop  shops  and 
clarifying planned energy savings for public buildings. 

212  The  modelling  framework  used  to  develop  the  scenarios  and  the  related  results  are  available  on  the 
Umweltbundesamt’s website: Umweltökonomische Analysen mit dem MIO-ES-Modell. 

188 

 
 
 
 
 
 
•  On industry, develop a comprehensive plan for promoting the use of renewable energy 
and boost energy efficiency.  Implement the Carbon Management Strategy, which includes 
establishing a comprehensive legal framework for the deployment of CCUS technologies 
and developing a plan for the rollout of CCUS infrastructure and operations. 

•  On renewable energy, put in place a favourable framework to support renewables-based 
electrification  across  sectors,  increase  awareness  amongst  citizens  and  companies  on 
financing possibilities and system benefits of renewable energy technologies. Promote the 
deployment of innovative renewable energy technologies to contribute to the indicative 
target of 5% by 2030 of the revised RED II. Develop a strategy to significantly increase 
the acceptance of wind power, involving local communities and considering biodiversity. 
•  On energy efficiency, put  in  place measures to  achieve the higher ambition  for  energy 

efficiency by 2030 for primary energy consumption.  

•  Further increase system flexibility, for instance by introducing measures to facilitate the 

uptake of power purchase agreements in industry.  

189 

 
 
 
 
 
 
 
 
Portugal 

1  Overview of key objectives, targets and contributions in the final NECP 

Final updated NECP submitted on 03.12. 2024 

Table 1: Summary of key objectives, targets and contributions of Portugal’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

2022: -18.2% 
2023: -18.6%213 

-28.7% 

NECP:  
-39.4% 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for 
additional net GHG 
removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 

Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

National contribution for 
energy efficiency: 

2022: Reported 
net removals of 
-5.93Mt CO2 eq.  

-0.97 Mt CO2 
eq. (additional 
removal 
target) 

34% 
(SHARES) 
31% 
(target) 

2023: 35.2% 

51% 

Primary energy 
consumption  

22.5 Mtoe 

2023: 20.71 
Mtoe 

16.71 Mtoe 

Projecting to meet 
the target: An 
overachievement 
of -11.91 Mt CO2 
eq compared to 
the 2030 target 

PT contribution of 
51% is in line 
with the level 
required 
according to the 
formula set out in 
Annex II of the 
Governance 
Regulation214 

PT primary 
energy 
consumption 
contribution is 
16.71 Mtoe. EED 
recast Annex I 
formula results: 
15.16 Mtoe 
(Reference 
Scenario) or 16.71 
Mtoe (Updated 
Reference 
Scenario) 

213 
The  ESR emissions  in 2022 are based on  2024  final  GHG inventory  reports, and 2023 emissions are 
based on 2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as 
set out in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions 
for 2021-2025 will only be established in 2027 after a comprehensive review. 
214 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’). 

190 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
Final energy consumption 

17.4 Mtoe 

2023: 17.20 
Mtoe 

14.37 Mtoe 

Level of electricity 
interconnectivity (%)215 

8.08% 

2024: 11.5% 

15% 

Source: Eurostat; Portugal’s final updated national energy and climate plan 

PT final energy 
consumption 
contribution of 
14.37 Mtoe is in 
line with the 
national 
contribution of 
14.37 Mtoe 
submitted by the 
Commission. 

PT is below the 
EU-wide 
interconnectivity 
target. 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In  December  2023,  the  Commission  published  a  thorough  assessment  of  Portugal’s  draft 
updated  NECP  and  provided  recommendations 216 for  the  preparation  of  the  final  updated 
NECP. Portugal submitted its final updated NECP on 3 December 2024, over five months after 
the deadline of 30 June 2024217. 

2.1  DECARBONISATION 

Based  on  the  projections  available  in  the  NECP,  Portugal  expects  to  decrease  total  GHG 
emissions (excluding LULUCF and excluding international aviation) by 37% in 2030 and by 
63% in 2040 compared to 1990218.  

2.1.1  Effort Sharing Regulation 
Portugal has addressed recommendation 1. The final NECP provides sufficient details on 
how Portugal will meet its ESR target of -28.7% by 2030 compared to 2005.  

Portugal  has  provided  projections  showing  that  with  existing  and  planned  policies  and 
measures Portugal will decrease emissions by 39.4% by 2030 compared to 2005, overachieving 
their target by 10.7 percentage points. However, Portugal has accounting debit gaps under the 
LULUCF Regulation, which are projected to impact its performance under the ESR. In 2023, 
GHG emissions from ESR sectors represented 75% of the total in Portugal (expected to reach 
71% in  2030219), with  transport representing  the largest  share. The WAM  value for ESR in 

215 Calculated by the European Commission based on the ENTSO-E data (Winter Outlook 2024).  The 2020 figure 
covers also interconnectors with the neighbouring countries outside the EU. The 2030 level represents the general 
interconnectivity target of 15%. 
216 SWD(2023) 922 final, and Commission Recommendation of 18 December 2023, C/2023/9612. 
217 Article 14(2) of Governance Regulation. 
218 Calculated based on the EEA reported 1990 figure and the projections provided by Portugal in the final updated 
NECP. 
219 The 2023 emissions are based on 2024 approximated inventory reports. 

191 

 
 
 
 
 
 
 
 
 
2030 is roughly 12% lower than the WEM, hinting that implementing the plan will require a 
significant effort.    

The  final  plan  complemented  the  information  on  the  policies  and  measures  provided  in  the 
draft but  could  still benefit from  a  clearer  description of their scope, timeline and  expected 
impact. The plan covers all ESR sectors comprehensively. On transport, the WAM projections 
describe a steep decrease in  emissions in the period 2022-2030, with the annual percentage 
change significantly decreasing compared to the period 2015-2022 (from +0.6% to – 5.7%)220. 
While  the  plan  promotes  public  transport  and  active  travel,  the  plan  reports  an  increase  in 
private  vehicle  ownership,  including  electric  vehicles.  The  plan  includes  measures  to 
incentivise EV but without specific targets or detailed plans to roll out charging infrastructure. 

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings, road transport and additional sectors (ETS2). The scenarios adequately account for 
the  effects  of  Portugal’s  national  carbon  tax  and  the  implementation  of  ETS2,  but  do  not 
quantify their impact in achieving the ESR target.  

On agriculture, the plan provides sufficient detail in terms of funding and impacts of measures, 
and  how  these  contribute  to  the  ESR  target.  On  waste,  the  plan  presents  several  relevant 
policies and shows significant reductions. On F-gases, the plan shows a stark contrast between 
the WEM and WAM scenarios, with emissions projected to increase by 94% by 2030 compared 
to  2005  under  WEM,  but  decrease  by  89%  under  WAM,  highlighting  the    importance  of 
monitoring implementation. 

2.1.2  LULUCF 
Portugal has addressed the recommendation 3. Policies in the LULUCF sector will result 
in  increased  net  removals  compared  to  2022  values.  The  final  plan  includes  projections 
indicating that Portugal will overachieve its target to deliver additional - 0.97 Mt CO2 eq. net 
removals in 2030.  

The plan provides minimal information on how mainly public funding (CAP, CF/SF, State Aid, 
etc)  will  be  used  to  ensure  fulfilment  of  LULUCF  target.  The  plan  provides  sufficient 
references on planned measures towards ensuring progress in the implementation of MRV in 
the LULUCF sector. 

2.1.3  Carbon Capture and Storage 
Portugal has partially addressed recommendation 2. The plan explains that Portugal will 
develop a CCUS strategy and estimates that 95 kt of CO2 will be captured annually by 2030, 
thanks to additional measures  (though  these measures  are not  specified).  The plan does not 
provide estimates of Portugal’s expected storage capacity, nor examples of planned/ongoing 
CCUS projects based in Portugal. 

2.1.4  Adaptation 
Portugal  has  partially  addressed  recommendation  4.  The  plan  refers  to  the  National 
Strategy  for  Adaptation  to  Climate  Change  (ENAAC  2020),  the  National  Climate  Change 
Programme (PNAC 2020-2030) and the National Adaptation Roadmap 2100 (RNA2100) to 
respond  to  the  recommendation,  acknowledging  the  importance  of  integrating  adaptation 

220 Compound annual growth rate. 

192 

 
 
 
 
 
 
planning.  The  plan  also  partially  embeds  adaptation  policies  and  measures  in  the  relevant 
Energy Union dimensions.  

The  plan  contains  a  thorough  analysis  of  climate  vulnerabilities  and  risks.  Grounded  in 
different  climate  scenarios  outlined  in  the  RNA2100,  the  plan  identifies  several  significant 
risks, such as forest fires, drought, coastal erosion, flooding and fluctuations in wind and solar 
energy, which could influence the resilience and functionality of the energy system. However, 
the plan is short of a quantifiable assessment of impacts. The plan outlines the links to specific 
Energy Union objectives and policies that adaptation measures are meant to support. It links 
measures  and  their  contribution  to  the  objectives  and  policies  of  the  five  Energy  Union 
dimensions.  However, the impacts and benefits of adaptation policies and measures on them 
have generally not been quantified.  

The plan partially addresses the consequences of climate change on future water availability. 
It lacks a fully comprehensive forward-looking assessment of future water demand and supply 
at  the  national  scale,  aligned  with  expected  climate  warming  trajectories.  It  also  does  not 
adequately  address  possible  cross-sectoral  conflicts  such  as  with  energy  production, 
agriculture, and residential water use in the face of growing water scarcity.  

2.1.5  Fossil Fuels 
Portugal has not addressed recommendation 19.  The plan indicates the need to phase out 
fossil fuel subsidies in line with international commitments and mentions the intention to phase 
out by 2030 fiscal advantages related to the use of fossil fuels. However, it does not provide a 
clear explanation of the specific measures and timeline Portugal intends to adopt to phase out 
fossil fuel subsidies. 

2.2  RENEWABLES  

Portugal  has  addressed  recommendation  5.  The  plan  puts  forward  an  increased  national 
contribution  for  renewable  energy  of  51%  share  of  renewables  in  gross  final  energy 
consumption in 2030. This contribution is in line with the level calculated in line with formula 
of Annex II of the Governance Regulation. The updated indicative trajectory to reach the 51% 
contribution in 2030 is provided, including specific reference points for 2025 (41%) and 2027 
(47%), which are above the trajectory calculated in line with the increased EU 2030 renewable 
energy target of 42.5% (40% for 2025 and 44% for 2027 respectively). 

Portugal has partially addressed recommendation 6. The plan states that offshore wind and 
wave capacity will lead to the achievement of the indicative target for innovative renewable 
energy technologies of at least 5% by 2030. However, the plan falls short of specifying targets 
to achieve the sectoral targets for industry, buildings and for heating and cooling of Directive 
(EU)  2018/2001  (the  ‘revised  RED  II’)221.  The  plan  does  not  include  a  specific  target  for 
renewable  fuels  of  non-biological  origin  (RFNBOs)  in  industry  by  2030.  Nevertheless, 
Portugal  indicates  that  it  plans  in  line  with  its  National  Hydrogen  Strategy  to  install  the 
electrolysers with 3 GW of net production capacity by 2030. Portugal has not included the sub-
target  for  advanced  biofuels  and  RFNBOs  for  transport  by  2030,  albeit  referring  to  the 

221 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  

193 

 
 
 
 
 
 
mandatory ones set by the revised RED II, deferring its definition to the transposition of the 
revised RED II itself.  

Portugal has addressed recommendation 7. The updated plan provides further information 
on power purchase agreements for which a legal framework will be put in place in line with 
the Regulation amending the Electricity Market Design, to promote and facilitate the use of 
such contracts in the long term while preserving the competitive and liquid electricity market.  

Portugal has addressed partially recommendation 8. The updated plan includes information 
on biomass supply projections, differentiating between domestic production and import. But 
the  plan  lacks  including  an  assessment  of  the  compatibility  of  the  projected  use  of  forest 
biomass  for  energy  production  with  Portugal’s  obligations  under  the  revised  LULUCF 
Regulation.  Portugal  includes  further  measures  to  promote  the  sustainable  production  of 
biogas/biomethane but expresses its target as a percentage of gas consumption in 2030. 

Portugal has partially addressed recommendation 9 as the plan does not provide a detailed 
overview of timelines and procedural steps for all policies and measures. 

2.3  ENERGY EFFICIENCY DIMENSION 

Portugal  has  partially  addressed  recommendation  10.  Portugal  includes  an  indicative 
national contribution of 14.4 Mtoe to the Union’s binding final energy consumption target for 
2030 and an indicative national contribution of 16.7 Mtoe to the Union’s indicative primary 
energy consumption target for 2030, both in line with Article 4 of Directive (EU) 2023/1791 
(‘EED recast’)222. 

However,  the  plan  does  not  include  the  amount  of  energy  consumption  reduction  to  be 
achieved by all public bodies annually. Portugal does not report the total floor area of heated 
and cooled buildings owned by public bodies to be renovated yearly - nor the corresponding 
yearly energy savings to be achieved223 nor does it specify if it opted for alternative or default 
approach. 

Portugal  has  partially  addressed  recommendation  11.  Portugal  sets  out  policies  and 
measures to achieve the national contributions on energy efficiency but does not quantify the 
expected  energy  savings  and  the  contribution  for  each  of  the  reported  measure.  The  main 
measures  include  the  promotion  of  renovations  of  multi-apartment  buildings,  coupled  with 
financing  and  technical  assistance,  as  well  as  the  development  of  municipal  and  regional 
climate  action  plans.  Portugal  specifies  how  the  energy  efficiency  first  principle  will  be 
implemented but did not mention any implementation measures.224 Portugal sets out policies 
and measures to achieve the required amount of cumulative end-use energy savings by 2030, 
but it does not quantify the energy savings from the reported energy efficiency measures. 

Portugal specified robust energy efficiency financing programmes and support schemes but 
did not specify existing policy measures to promote the uptake of energy efficiency lending 
products  and  innovative  financing  schemes,  as  well  as  Energy  Performance  Contractors,  or 

222 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 
223 The NECP sets targets of energy savings for all buildings, including various types of public buildings by 2050. 
224 It specified that building renovation and ZEB will play an important role. 

194 

 
 
 
 
 
 
ESCOs225. Portugal established a National Energy Efficiency Fund, but it did not detail its role 
nor provided sufficient information on its functioning. 

Portugal has not addressed recommendation 12.  Portugal included intermediate milestones 
for 2030 and 2040. The final plan includes objectives (primary and final energy savings, area 
of intervention, investment) for residential and non-residential buildings for 2030 which refer 
to the LTRS of Portugal (Estratégia de Longo Prazo para a Renovação dos Edifícios (ELPRE). 
The final plan also includes objectives for 2040 and 2050 for residential and non-residential 
buildings which provide target values for a number of indicators (e.g. primary and final energy 
savings, share of renewables, percentage reduction of CO2 emissions, etc). However, the level 
of ambition itself has not been increased.  

The NECP contains information on the related measures for buildings and provides figures on 
the expected energy savings. The related measures are estimated to result in primary energy 
savings of 40% in residential buildings and 28% in non-residential buildings, and in total 34% 
by 2050. The plan indicates that the combination of measures and action by the private sector 
should  guarantee  all  buildings  in  existence  in  2018  are  renovated  by  2050  (if  still  in  use). 
However, information on the deployment of the measures or allocated budgets is not clear. 

2.4  ENERGY SECURITY DIMENSION 

Portugal has partially addressed recommendation 13.  Portugal raises the target for battery 
storage capacity to 2 GW in 2030, as opposed to 1 GW in the draft plan, while pumped hydro 
installed capacity remains the same (3,9 GW).  

The oil section of the updated plan did not undergo significant changes, and thus it does not 
assess the long-term adequacy of Portugal’s oil infrastructure (including refinery, oil stocks) 
with the expected decline in oil demand and the move toward lower-carbon alternatives. 

The  plan  acknowledges  the  need  for  the  energy  sector  to  consider  climate  variability  and 
climate  change  and  sets  out  a  commitment  to  develop  a  sectoral  climate  change  adaptation 
plan.  

2.5  INTERNAL ENERGY MARKET DIMENSION 

Portugal has partially addressed recommendation 14. The plan does not elaborate on the 
quantification  of  flexibility  needs,  nor  does  it  set  clear  targets  and  objectives  for  demand 
response and to improve the flexibility of the energy system. While it references the promotion 
of market aggregators and the roll-out of smart meters to facilitate demand participation, some 
of these initiatives lack detailed measures or defined timelines. The plan does include policies 
and measures that support flexibility. Portuguese authorities are evaluating ongoing projects 
on  demand  participation  and  flexibility  services,  but  these  initiatives  lack  a  comprehensive 
framework and clear objectives. Even though the plan provides measures promoting flexibility 
solutions  in  the  context  of  facilitating  energy  system  integration,  it  does  not  provide 
information on specific measures for implementing Article 20a of the revised RED II.  

225 It mentions such mechanisms only as topics for research projects. 

195 

 
 
 
 
 
 
 
The plan also includes a measure on citizens’ empowerment (education and training) for low-
carbon  behaviours  and  more  sustainable  production  and  consumption  patterns,  as  well  as 
measures of consumers empowerment in self-consumption, focusing on individual, collective 
self-consumption and renewable energy communities. The plan recognizes the importance of 
consumer education, empowerment and engagement through energy literacy campaigns and 
access to new technologies that increase energy efficiency and offer innovative solutions.  

Portugal has partially addressed recommendation 15. The plan includes an assessment of 
the  situation  of  affected  households  and  specific  measurable  targets.  Portugal  provides 
additional details on existing and potential measures to address energy poverty. In particular, 
Portugal has developed a National Long-Term Strategy to Combat Energy Poverty (ELPPE) 
with  the  goal  to  eradicating  energy  poverty  by  2050.  The  plan  also  includes  measures  to 
promote the creation and development of renewable energy communities and one stop shops, 
which  can  contribute  to  addressing  energy  poverty,  thus  linking  the  consumer  protection 
agenda to the consumer empowerment in a coherent way. However, there is no clarity on the 
dedicated financial resources from the perspective of both social policy and structural energy 
measures.  The  plan  explains  how  the  use  of  energy  efficiency  measures  will  contribute  to 
alleviating energy poverty. 

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Portugal  has  partially  addressed  Commission  recommendation  16.  The  plan  includes 
national objectives for research and innovation in energy for 2030. Compared to the draft, the 
final  plan  establishes  a  more  developed  approach  to  support  research,  innovation,  and 
investments in clean energy technologies, for instance through initiatives to strengthen the link 
between research and innovation activities and the business sectors. The plan lacks information 
on  concrete  initiatives  to  promote  the  manufacturing  of  clean  energy  technologies  and 
equipment.  It  does  not  describe  a  predictable  and  simplified  regulatory  framework  for 
permitting procedures for manufacturing facilities. The plan does not provide detailed policies 
and measures for the digitalisation of the energy system. The plan highlights the importance of 
clean-energy related skills and puts forward a measure to promote training and reskilling for 
the energy and climate transition. 

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Portugal  has  not  addressed  recommendation  17.  The  plan  does  not  provide  data  on 
investment needs. Nonetheless it provides a broad description of the main sources of financing 
for each measure. The plan does not outline how the planned measures will mobilise private 
investments  and  does  not  include  a  split  of  public  and  private  investments.  Overall,  the 
information provided in the plan is not sufficient to assess a potential financing gap with respect 
to the investment needs, or how this would be filled.  

Portugal has partially addressed the recommendation to provide a robust assessment of 
the macroeconomic impact of the planned policies and measures. 

196 

 
 
 
 
 
2.8  JUST TRANSITION 

Portugal  has  partially  addressed  Commission  recommendation  20.  The  plan  provides 
information on the impact of the transition to climate neutrality on employment, training, and 
skills, but does not sufficiently detail the actions, the target groups and the dedicated resources. 
Despite the increasing emphasis on energy poverty as a just transition element, the plan does 
not assess other distributional impacts of the climate and energy transition and on the planned 
objectives, policies and measures to support a just transition. Moreover, the plan gives only 
general information on the form of support, the impact of initiatives or the resources available, 
except for the Just Transition Fund (JTF). The plan lacks a concrete description of the initiatives 
and resources to translate the commitments into action.  

The plan is aligned with the Territorial Just Transition Plans, the phase-out date of fossil fuels 
is maintained. In particular, while Portugal has closed its last mine in 2021, it also plans to stop 
producing electricity from coal by 2030 at the latest. 

The plan partially provides the analytical basis needed for the preparation of the Social Climate 
Plan, such as information on the monitoring of vulnerable groups in energy poverty. The plan 
does not clearly explain how the policy framework identified in the NECP will contribute to 
the preparation of Portugal’s Social Climate Plan. Nonetheless, the NECP explains how the 
consistency of the two plans will be ensured.  

2.9  PUBLIC CONSULTATION 

Portugal  has  addressed  recommendation  21.  Portugal  organised  two  rounds  of  public 
consultations to prepare the final plans, and organised various exchanges with stakeholders, 
including  social  partners,  civil  society  and  the  general  public  (also  through  Participatory 
Assemblies). The public consultations were organised through an online portal. The first round, 
on the draft updated NECP, (with a questionnaire) took place from 15 March to 14 April 2023, 
before the submission date in June 2023. It collected 59 contributions from various sectors of 
the economy. The second round, on the draft final integrated NECP, took place from 22 July 
to  5  September  and  attracted  increased  interest,  with  177  participations  and  more  detailed 
comments. The plan includes a detailed summary of the outcome of the consultations, describes 
in  a  limited  way  how  the  final  plan  integrates  the  inputs  and  changes  suggested  from 
stakeholders, and explains why certain inputs were not included. 

2.10 REGIONAL COOPERATION 

Portugal has partially addressed recommendation 22. The plan includes a detailed list of 
initiatives  aimed  at  increasing  Portugal’s  engagement  with  neighbouring  Member  States, 
including in the context of the High-Level Group on Interconnections for South-West Europe. 
It refers to the negotiations to sign the solidarity agreement for gas supply with Spain which is 
in the final stage of preparation. The plan does not describe how Portugal plans to establish a 
framework  for  cooperation  with  other  Member  States  by  2025  in  line  with  Article  9  of  the 
revised RED II.  

197 

 
 
 
 
 
2.11 ANALYTICAL BASIS 

The final plan is based on solid quantitative analysis and the methodologies used for projections 
and the impact assessment are clearly explained and referenced. The assessment of economic 
and social impacts has been further developed compared to the draft updated NECP. The plan 
now  includes  the  impacts  of  scenarios  on  main  economic  aggregates  such  as  GDP, 
employment, private consumption and investments.   

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

Portugal has addressed recommendation 18. The plan covers sufficiently the main reforms 
and investments of the Recovery and Resilience Plan (RRP) that contribute to implementing 
the objectives, targets and contributions of the Energy Union.   

3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

The Commission encourages Portugal to ensure a timely and complete implementation of the 
final  updated  NECP.  Portugal  is  invited  to  pay  particular  attention  to  the  following  main 
elements: 

•  On LULUCF, monitor implementation as the projected sink to meet the 2030 target relies 
on a reduction of burnt areas, a reduction of harvesting or an increase of forest area. It is 
crucial to ensure that use of biomass in the energy sector does not negatively impact the 
achievement of the sequestration target under the LULUCF sector.  

•  Closely  monitor  the  impacts  of  transport  policies,  as  a  significant  part  of  projected 
emissions reduction is driven by measures that are not yet fully in place. Notably, consider 
promoting  holistic  approach  promoting  alternative  mobility  solutions,  the  expansion  of 
charging infrastructure and incentives for EVs.  

•  On  adaptation,  use  the  vulnerability  assessment  already  developed  in  the  National 
Adaptation Roadmap as a basis for the 2025 review of the National Adaptation Strategy 
and  the  subsequent  review  of  the  regional  and  municipal  adaptation  plans.  Establish 
specific, measurable adaptation measures and targets.   
 Develop a roadmap with specific measures to phase out fossil fuel subsidies.  

• 
•  As regards renewable energy, put in place the planned measures to facilitate the uptake of 
power purchase agreements, thereby ensuring certainty to market actors as over 95% of the 
electricity generation is expected to be from renewable sources.  

•  Set additional measures to ensure the necessary grid developments, including streamlined 
permitting  and  capacity  allocation  process,  as  well  as  developing  network  storage  and 
flexibility. Develop a more structured approach to enhancing energy system flexibility.  
•  Prioritise the use of renewable gases and green hydrogen in sectors with hard to abate 
emissions  where  electrification  is  not  feasible  given  the  energy  intensity  and  costs 
associated with the production of these renewable gases.  

•  On energy efficiency, develop adequate measures targeting the public sector, including the 
renovation of public buildings. In this context, proper implementation of Articles 5 and 6 
EED recast is crucial.   

198 

 
 
 
 
 
•  Regarding the heating and cooling sector, continue efforts on the renovation of buildings, 
to  promote  energy  efficiency  and  reduce  energy  poverty.  Prioritise  the  use  of  high-
efficiency heat pumps to promote electrification of the heating and cooling sector. 

•  Develop a more comprehensive just transition strategy that allocates appropriate financial 

resources. 

199 

 
 
 
 
 
 
Romania  

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Romania’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

2022: +4% 
2023: +3.8%226 

-12.7% 

NECP:  
-15.3% 

Reported net 
removals of  -
46.5 Mt CO2 eq. 
in 2022 

-2.38 Mt CO2 
eq. (additional 
removal 
target) 

%  24.5% 
(SHARES) 

24% 
(target) 

2022: 24.2% 

2023: 25.8% 

38.3% 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for net 
GHG removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 

Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

National contribution for 
energy efficiency: 

Primary energy 
consumption  

43 Mtoe 

2023: 30.0 Mtoe 

28.7 Mtoe 

Final energy consumption 

30.3 Mtoe 

2023: 23.3 Mtoe 

22.5 Mtoe 

226 
The  ESR emissions  in 2022 are based on  2024  final  GHG inventory  reports, and 2023 emissions are 
based on 2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as 
set out in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions 
for 2021-2025 will only be established in 2027 after a comprehensive review. 
227 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’). 

200 

Insufficient 
ambition: 
projected gap of 2 
Mt CO2 eq. in 
2030  

RO contribution 
of 38.3% is below 
the required 41% 
in line with the 
formula set out in 
Annex II of the 
Governance 
Regulation227 

RO primary 
energy 
consumption 
contribution is 
28.7 Mtoe. EED 
recast Annex I 
formula results: 
30.2 Mtoe (2020 
EU Reference 
Scenario) and 28.9 
Mtoe (Updated 
Reference 
Scenario) 

RO final energy 
consumption 
contribution of 
22.5 Mtoe is in 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
Level of electricity 
interconnectivity (%)228 

9.3% 

2024: 16.3% 

15% 

Source: Eurostat; Romania’s final updated national energy and climate plan 

line with the 
national 
contribution of 
22.5 Mtoe 
submitted by the 
Commission. 

RO has surpassed 
the EU-wide 
interconnectivity 
target 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In  December  2023,  the  Commission  published  a  thorough  assessment  of  Romania’s  draft 
updated  NECP  and  provided  recommendations 229 for  the  preparation  of  the  final  updated 
NECP. Romania submitted its  final  updated NECP on 14 October 2024, over three months 
after the deadline of 30 June 2024230. 

2.1  DECARBONISATION 

Romania  expects  to  decrease  total  GHG  emissions  (including  LULUCF  and  excluding 
international aviation) by 85% in 2030 and 96% in 2040 as compared to 1990, and to reach 
climate neutrality by 2050. 

2.1.1  Effort Sharing Regulation 
Romania  has  addressed  recommendation  1.  The  plan  provided  sufficient  details  on  how 
Romania will meet its ESR target of -12.7% by 2030 compared to 2005.  

The plan provides projections showing that the existing and planned policies and measures will 
lead to a decrease of 15.3% in 2030 compared to 2005, overachieving the national ESR target 
by 2.6 percentage points. In 2023, GHG emissions from ESR sectors represented 77% of the 
total in Romania (expected to be 79% in 2030)231, with transport and agriculture representing 
the largest shares. The ‘with additional measures’ (WAM) projected value in 2030 is roughly 
7% lower than the projections under the ‘with existing measures’ (WEM) scenario, hinting that 
implementing the plan will require additional effort.  

The final plan complemented the information on most of the policies and measures provided 
in the draft but at times still lacks details on their timeline and expected GHG reduction. On 
transport, the WAM projections describe a decrease in emissions in the period 2022-2030, with 
the average percentage decrease per year of 3 times larger than in the period 2015-2022 (from 

228 
Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2024). The 2020 
figure also covers interconnectors with the neighbouring countries outside the EU. The 2030 level represents the 
general interconnectivity target of 15%.  
229 SWD(2023) 930 final, and Commission Recommendation of 18 December 2023, C/2023/9620. 
230 Article 14(2) of Governance Regulation. 
231 The  2023  emissions  are  based  on  2024  approximated  inventory  reports  and  2030  is  based  on  reporting  of 
greenhouse gas projections (Article 18 of the Governance Regulation). 

201 

 
 
 
 
 
 
 
4.29%  to  1.36%) 232 .  The  plan  focuses  on  increasing  alternatively  fuelled  vehicles  and 
modernising  public  transport  but  lacks  clarity  on  implementation.  Moreover,  the  plan  lacks 
information  on  policies  and  measures  addressing  the  two  biggest  sources  of  non-CO2 
emissions, namely N2O from agricultural soils and CH4 from coal, oil and gas.  

The plan does not refer to the introduction of the emissions trading system for fuel combustion 
in  buildings,  road  transport  and  additional  sectors  (ETS2).  The  scenario  projections  do  not 
account for the effect of ETS2.  

2.1.2  LULUCF 
Romania has not addressed recommendation 3. The LULUCF sector in Romania generates 
net removals, absorbing roughly 42.3% of the total GHG emissions in 2022. Romania has to 
enhance  its  net  removals  by  -2.38  MtCO2eq  in  2030  compared  to  the  reference  period. 
According  to  2022  figures,  Romania  has  worsened  its  performance  by  -2.2  MtCO2eq  in 
comparison to its yearly average in the 2016-2018 reference period. Considering its projections 
for  2030,  Romania  will still  have  a  gap  of  2  MtCO2eq  in  2030.  The  plan  indicates  that  for 
LULUCF there are no additional policies compared to the baseline scenario.   

The plan does not provide sufficient information on how public funding (CAP, State aid) and 
private financing through carbon farming schemes are used to reach the LULUCF target.  It 
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. 

2.1.3  Carbon Capture and Storage 
Romania has partially addressed recommendation 2. The plan envisages the development 
of a comprehensive national carbon management strategy but does not provide clear annual 
injection capacity targets for 2030. The plan provides estimates of the total need of CO2 capture 
(62 million tonnes per year, though the source is not defined), the total CO2 transportation via 
pipelines capacity in Romania (16 million tonnes per year) and the total CO2 storage capacity 
(9 million tonnes per year), though the timing is not clearly indicated. The plan outlines that 
CCUS  legislation is in  place or under development,  and that a €750 million  budget  will be 
reserved to implement CCUS technologies, mostly using EU financing instruments. 

2.1.4  Adaptation 
Romania  has  partially  addressed  recommendation  4.  The  plan  refers  to  the  National 
Strategy  for  Adaptation  to  Climate  Change  for  the  period  2024-2030  (SNASC)  and  the 
National  Action  Plan  for  Adaptation  to  Climate  Change  (PNASC)  to  respond  to  the 
recommendation, acknowledging the importance of integrating adaptation planning. The plan 
also  partially  embeds  adaptation  policies  and  measures  in  the  relevant  Energy  Union 
dimensions.   

The plan contains a partial analysis of climate vulnerabilities and risks. The plan, referencing 
the SNASC, outlines objectives for 13 key sectors, including reducing water scarcity and flood 
risks, adapting forest management to climate change, expanding forested areas, and enhancing 
resilience  of  the  energy  sector  and  critical  infrastructure.  However,  the  plan  is  short  of  a 

232 Compound annual growth rate. 

202 

 
 
 
 
 
 
quantifiable  assessment  of  impacts.  The  plan  outlines  the  links  to  specific  Energy  Union 
objectives and policies that adaptation measures are meant to support. It links the key sectors 
mentioned  in  the  SNASC  such  as  water  resources,  forestry,  and  energy  sector  with  the 
objectives  and  policies  of  the  five  Energy  Union  dimensions.  However,  the  impacts  and 
benefits  of  adaptation  policies  on  other  Energy  Union  objectives  have  generally  not  been 
quantified. The plan sets some additional adaptation policies and measures to support the 
achievement of national objectives, targets and contributions under the Energy Union. While 
the plan highlights the need for strategic adaptation objectives to align with other policies, and 
emphasizes  legislative  and  policy  measures  that  incorporate  nature-based  solutions,  the 
measures provide insufficient details to assess their scope, financing, timing, and likely impact. 
However, the creation of RO-Adapt platform for climate data is a positive step.  

2.1.5  Fossil Fuels 
Romania  has  not  addressed  recommendation  18.  The  plan  includes  the  Territorial  Just 
Transition Plans (TJTPs) commitments to phase down coal by 2032. However, the timeline for 
the  phase-out  of  coal  and  lignite-based  power  plants  is  not  indicated.  The  plan  does  not 
sufficiently  explain  the  alignment  with  the  TJTPs  as  it  does  not  clarify  the  intermediate 
trajectory and milestones for the phase out of fossil fuels. 

The plan did not include commitments to phase out fossil fuel subsidies. The Law 226/2021 
on the establishment of social protection measures for vulnerable energy consumers  lists an 
increased  number  of  general  subsidies,  without  specifically  identifying  the  fossil  fuels 
subsidies. 

2.2  RENEWABLES  

Romania has partially addressed recommendation 5. The plan includes an increased share 
of renewable energy contribution of 38.3% in gross final energy consumption by 2030, based 
on  WAM  scenario.  However,  it  remains  below  the  level  (of  41%)  calculated  in  line  with 
formula  of  Annex  II  of  the  Governance  Regulation.  The  updated  indicative  trajectory  for 
achieving  the  increased  contribution  was  also  provided  with  the  reference  points  for  2025 
(31%) and 2027 (33.6%). The reference point for 2027 is below the trajectory (35%) calculated 
in line with the EU 2030 renewable energy target of 42.5%.  

Romania has taken sufficient measures to cover the gap towards its 2021 renewables baseline 
which must not be lower than its mandatory national overall target for the renewable energy 
share in 2020, in line with Article 32(4) of Governance Regulation. 

Romania has partially addressed recommendation 6. The plan provides projections for the 
deployment of renewable energy technologies over the next 10 years, with an outlook to 2040. 
The plan includes projections in buildings and industry for 2030, advanced biofuels and the 
RFNBOs in transport by 2030; however, the plan does not confirm whether those constitute 
the  specific  targets  to  achieve    the  sub-targets  in  line  with  Directive  (EU)  2018/2001  (the 
‘revised  RED  II’)233,  and  the  plan  does  not  include  information  on  the  RFNBO  target  for 
industry Romania confirmed its plans to meet the binding average increase of renewables in 

233 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  

203 

 
 
 
 
 
 
heating and cooling for both 2021-2025 and 2026-2030 periods. Over both periods, the increase 
is close to the indicative level of the top-up in line with Annex IA of the revised RED II. The 
plan  does  not  include  an  indicative  target  for  innovative  renewable  energy  technologies  by 
2030 in line with the revised RED II. 

Romania  has  partially  addressed  recommendation  7.  Romania  provides  additional 
information on policies and measures, including specifying an estimated budget and the sources 
of  financing.  The  plan  provides  further  detail  on  measures  aimed  at  ensuring  an  enabling 
framework  to  promote  self-consumption  and  energy  communities.  However,  no  further 
information  was  included  on  how  Romania  plans  to  accelerate  permitting  and  designate 
renewables acceleration areas, including which renewable energy technologies will be covered. 
The  plan  does  not  elaborate  on  the  uptake  of  renewable  power  purchase  agreements  and 
guarantees  of  origin.  It  does  not  provide  further  indications  on  an  enabling  framework  for 
increasing integration between electricity and heating and cooling networks. Romania does not 
provide further information on measures for promoting renewable hydrogen in industry and in 
transport. 

Romania has partially addressed recommendation 8. The plan includes an assessment of 
the compatibility of the projected use of forest biomass for energy production with Romania’s 
obligations under the revised LULUCF Regulation but does not provide an assessment of the 
domestic supply of forest biomass for energy purposes in 2021-2030 in accordance with the 
strengthened sustainability criteria of Article 29 of the revised RED II. Romania also included 
measures to promote the sustainable production of biogas and biomethane. 

Romania has not address recommendation 9. The plan does not include information on the 
expected  timeline  and  the  steps  leading  to  the  adoption  of  legislative  and  non-legislative 
policies and measures  aimed at  transposing  and implementing  the provisions of  the revised 
RED II. 

2.3  ENERGY EFFICIENCY DIMENSION 

Romania  has  partially  addressed  recommendation  10.  Romania  includes  an  indicative 
national  contribution  of 28.7 Mtoe  to  the Union’s  primary energy consumption target  for 
2030 234 .  This  contribution  is  in  line  with  Article  4  of  Directive  (EU)  2023/1791  (‘EED 
recast’)235236. However, Romania does not include the amount of energy consumption reduction 
per year to be achieved by all public bodies. Romania does not report the total floor area of 
heated  and  cooled  buildings  owned  by  public  bodies  to  be  renovated  yearly,  nor  the 
corresponding yearly energy savings to be achieved, and it also did not specify if it opted for 
the alternative or default approach. Romania includes the amount of cumulative energy savings 
of 10.1 Mtoe to be achieved over the period from 1 January 2021 to 31 December 2030, which 
is however not in line with Article 8 of EED Recast in terms of ambition. The plan also does 

234 The Romanian final NECP does not commit to a PEC target. Instead, the projected decrease in PEC (under the 
WAM  scenario)  is  compared  with  the  EED  target,  and  the  document  concludes  that  the  EED  target  will  be 
surpassed. 
235 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 
236 It  is  projected  to  surpass  by  4.8%  the  indicative  results  of  the  Article  4  and  Annex  I  formula  (REF2020 
scenario), and by 0.5% the indicative results of the Article 4 and Annex I formula (updated REF2020 scenario). 

204 

 
 
 
 
 
 
not include any explanation on how the annual savings rate and the calculation baseline were 
established. Moreover, values are inconsistently reported across the plan in primary or final 
energy consumption, thus being difficult to compare and assess. 

Romania  has  partially  addressed  recommendation  11.  Romania  sets  out  policies  and 
measures to achieve the required amount of cumulative end-use energy savings by 2030, but 
it does not  quantify the  energy savings from all  the reported  energy efficiency measures to 
ensure the achievement of the cumulative target. Romania does not include the quantification 
of the savings from those energy efficiency measures targeting energy poverty. Romania sets 
out adequate measures to promote energy audits and energy management systems. Romania 
does  not  specify  robust  energy  efficiency  financing  programmes  and  support  schemes, 
including financial instruments and public guarantees, able to mobilise private investments and 
additional co-financing. Romania specifies existing policy measures to promote the uptake of 
energy efficiency lending products and innovative financing schemes such as ESCOs.  

Romania has partially addressed recommendation 12. Romania does not include updated 
milestones in comparison to the Long-Term Renovation Strategy submitted in 2020 or the draft 
2023  NECP,  nor  detailed  the  impact  in  terms  of  energy  savings  of  each  new  measure  put 
forward. Nonetheless, Romania includes intermediate milestones for 2030 and 2040, further 
considers  non-residential  buildings  in  addition  to  residential  buildings,  and  emphasises  the 
increase of near zero energy buildings and the decrease in worst performing buildings within 
the projected increase of the annual renovation rate. Furthermore,  the plan does not include 
sufficient  information  on  related  measures  for  buildings  in  terms  of  energy  and  emissions 
savings,  funding,  and  costs.  However,  Romania  includes  some  information  on  policies  and 
measures  addressing  deep  renovation,  in  particular  of  worst-performing  buildings,  as  well 
specific  information  on  policies  and  measures  addressing  decarbonisation  of  heating  and 
installation of renewables in buildings. 

2.4  ENERGY SECURITY DIMENSION 

Romania has partially addressed recommendation 13. The plan does not provide further 
details on clear objectives for encouraging gas demand, nor does it assess the compatibility of 
the  national  gas  infrastructure  with  decarbonisation  objectives.  However,  the  plan  provides 
forecasts of the evolution of natural gas consumption, which is expected to increase from 8.4 
Mtoe in 2022 to 9.5 Mtoe by 2030 and then decrease to 5.4 Mtoe by 2040 and to 3.9 Mtoe by 
2050 (WAM scenario).   

The plan sets an objective of 1200 MW or 2400 MWh for battery storage for 2030 and a clear 
target  (800 MW)  for  pumped  hydro  storage.  A  projection  of  installed  battery  capacities  for 
2035 and 2040 was also provided. 

The plan was updated with projections on oil consumption until 2050 but does not include an 
assessment of the adequacy of the oil infrastructure in  the long  run (refineries, pipeline, oil 
stocks) with the expected oil demand decline and the move to lower-carbon alternatives.   

The NECP provides information on plans to expand Romania’s nuclear generation capacity by 
building new small modular reactors (SMRs) with a total installed capacity of 462 MW, and 2 
new  units  at  the  Cernavodă  NPP.  However,  the  plan  does  not  provide  information  on  the 
diversification and long-term supply of nuclear materials, fuel, spare parts, and services, or on 

205 

 
 
 
 
 
measures for long-term management of nuclear waste.  The latter is however covered in the 
4th  national  report  submitted  in  August  2024  in  accordance  with  Article  14  of  Directive 
2011/70/EURATOM.237   

The plan recognises the need to consistently implement strategic climate adaptation objectives 
of the National Strategy on Adaptation to Climate Change to increase energy system resilience.  
It does not, however, clearly put forward policies and measures to integrate the imperative of 
climate adaptation in the energy system. 

2.5  INTERNAL ENERGY MARKET DIMENSION 

Romania  has  partially addressed  recommendation  14.  The  plan  mentions  some  positive 
steps related to improving electricity interconnection capacity but does not set clear targets to 
improve the electricity interconnection capacity or set out a clear timeline for projects. With 
regards to non-fossil flexibility sources providing the right flexibility amount to the system, the 
plan  rather  focuses  on  the  benefits  of  energy  storage  and  does  not  provide  clear  targets  for 
demand response. Finally, the plan does not provide information on how to facilitate energy 
system  information  in  accordance  with  Article  20a  of  the  revised  RED  II,  nor  on  the 
organisation  of  electricity  markets  and  the  phasing  out  of  measures  interfering  with  market 
signals.  

The Plan includes measures for consumer protection and consumer empowerment. It provides 
updates on smart metering deployment and information on legislative measures for ensuring 
contractual rights for consumers. Romania has a dedicated program for energy communities.  

Romania  has partially addressed  recommendation 15. A measurable reduction target  on 
energy poverty was adopted based on the indicator ‘population unable to keep home adequately 
warm.’ Romania also sets up some clear objectives and measures to address energy poverty 
referring  to  ensuring  access  to  sustainable  and  diverse  energy  sources  for  households, 
vulnerable  energy  consumers  protection  and  governance  of  the  process  to  reduce  energy 
poverty.  However,  while  there  is  information  on  some  of  the  financial  resources  from  the 
perspective  of  structural  energy  measures,  there  is  no  overview  of  all  relevant  financial 
resources nor of potential further measures. 

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Romania has not addressed recommendation 14. The plan largely lacks a comprehensive 
approach  that  includes  targets  to  support  research,  innovation  and  competitiveness  in  clean 
energy technologies, the manufacturing of clean energy technologies and equipment, and the 
digitalisation of the energy value chain.  

The  Romanian  National  Strategy  for  Research,  Innovation,  and  Smart  Specialization  2022-
2027  (SNCISI)  includes  objectives  and  targets  which  apply  to  overall  R&I  activities  and 
includes  energy  and  mobility  as  one  of  the  six  priority  domains  for  national  smart 

237 Council Directive 2011/70/Euratom of 19 July 2011 establishing a Community framework for the responsible 
and safe management of spent fuel and radioactive waste. 

206 

 
 
 
 
 
 
 
specialisation. However, the specific national objectives and funding targets for clean energy 
remains unclear.  

The  plan  identifies  general  sources  for  financing  R&I  with  European  and  national  funding 
schemes but does not include a breakdown of investments in research and innovation targeted 
on the energy sector for 2030 and beyond. 

The plan does not include a pathway for 2030 and beyond to support the decarbonisation of 
industry and to promote the transition of businesses towards a net zero economy.  

The plan does not include measures to promote the development of net-zero projects including 
those  relevant  for  the  energy  intensive  industries.  It  does  not  describe  how  it  will  ensure  a 
predictable and simplified regulatory framework for permitting procedures for manufacturing 
or how access to national funding will be simplified where needed.  

Finally, the plan includes general mentions that the Romanian Recovery and Resilience Plan 
and  Just  Transition  funding  are  used  for  up-skilling  and  re-skilling  the  workforce  for 
participating  to  the  clean  energy  transitions,  but  it  did  not  provide  more  details  on  these 
policies. 

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Romania  partially  addressed  recommendation  17.  The  plan  provides  an  estimate  of  the 
overall investment needs of 4,193 billion EUR, and a breakdown by sector. The plan neither 
provides a complete overview of investment needs and funding sources nor quantifies the share 
of private and public investments. The plan does not explain which instruments will be used to 
mobilise private funding.  

The information  provided in  the plan is  not  sufficient to  assess  whether there is  a potential 
financing gap with respect to the investment needs, or how this would be filled.  

Romania has partially addressed recommendation 17 to provide a robust assessment of 
the  macroeconomic  impact  of  the  planned  policies  and  measures.  The  macroeconomic 
analysis focuses only on projected green job creation and estimated energy costs. The NECP 
lacks the macroeconomic impact assessment for certain policies, e.g. carbon pricing.   

2.8  JUST TRANSITION 

Romania has partially addressed recommendation 19. The final plan improves the analysis 
of the social, employment and skills impacts of the energy and climate transition, as part of the 
overall macro-economic assessment. It identifies the sectors in which most green jobs will be 
created but not the groups, sectors and regions likely to be most affected by the green transition 
in  terms  of  employment  losses.  The  plan  analyses  the  social  cost  associated  with  primary 
energy  consumption  up  to  2050  under  the  WEM  and  WAM  scenarios  and  emphasizes  the 
potential  benefits  of  implementing  further  energy  policies.  However,  it  fails  to  provide  a 
granular analysis of the social impacts on vulnerable groups. It also fails to provide information 
on reskilling and upskilling objectives and a clear breakdown of financing needs. Moreover, 
the plan does not specify the form of support, the impact of initiatives or the resources available, 
except for the JTF.   

207 

 
 
 
 
 
The plan does not provide the analytical basis needed for the preparation of the Social Climate 
Plan, such as information on the estimated impact of ETS2 and the identification of vulnerable 
groups, except for the definition of energy poverty, which is already established in Romania. 
The plan does not explain how the policy framework identified in the NECP will contribute to 
the preparation of Romania’s Social Climate Plan nor how the consistency of the two plans 
will be ensured.  

2.9  PUBLIC CONSULTATION 

Romania has not addressed recommendation 20. Romania organised three rounds of public 
consultations to prepare the final plan. The consultations on the final NECP were organised in 
the form of debates (respectively on 21 February, 28 February and 6 March 2024) attended by 
a range of stakeholders (e.g. NGOs, industry stakeholders and social partners). A wide range 
of policy measures were discussed. 

The plan includes a limited summary of the consultations but does not describe in detail how 
the final plan integrates the inputs. 

2.10 REGIONAL COOPERATION 

Romania has not addressed recommendation 21. The final updated NECP does not provide 
clarity on how Romania plans to intensify its cooperation with EU Member States and Energy 
Community  Contracting  Parties  within  the  Central  and  South  Eastern  Europe  Energy 
Connectivity High Level Group (CESEC HLG), especially in the context of the most urgent 
priority actions such as the harmonisation of the gas quality parameters and establishment of 
the firm capacities along the Trans-Balkan pipeline. Moreover, Romania does not explain how 
the  regional  cooperation  in  CESEC  could  support  an  improvement  in  the  electricity 
interconnection  capacity  and  particularly  the  realisation  of  electricity  infrastructure  projects 
between Romania and other countries in the region that have been identified as the CESEC 
priority  projects.  Romania  also  does  not  provide  additional  information  in  its  final  plan  on 
establishing the framework for cooperation on joint projects by 2025 in line with Article 9 of 
the revised RED II.  

The plan does not refer to progress nor efforts to be undertaken as regards the signature of the 
two  bilateral  solidarity  arrangements  for  the  security  of  gas  supply  with  its  neighbours 
(Hungary and Bulgaria). 

2.11 ANALYTICAL BASIS 

The analysis is based on bottom-up modelling and least-cost optimisation. However, modelling 
details are not documented extensively.  

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

The  final  NECP  sufficiently  covers  the  main  reforms  and  investments  of  the  Recovery  and 
Resilience  Plan  (RRP)  that  contribute  to  implementing  the  climate  and  energy  objectives 
targets and contributions. However, some of the investments and reforms are not adequately 
recognised as part of the RRP, for example the renovation of residential and public buildings. 

208 

 
 
 
 
 
Some measures included in the final updated NECP are less ambitious than those in the RRP, 
for example the installed renewable energy sources capacity by 2026, decarbonisation of the 
energy system with its replacement capacities and energy renovations of buildings. 

3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

Romania  needs  to  swiftly  proceed  with  implementing  its  final  updated  NECP.  Romania  is 
invited to pay particular attention to the following main elements:  

• 

Implement in a timely manner additional policies towards their ESR target as significant 
part of the emissions  reductions in  ESR are projected to  come from  policies not  yet  in 
place. 

•  Monitor the impacts on mitigation of CH4 emissions from the energy sector, given the 

relevance of the sectors. 

•  On adaptation, carry out a thorough assessment and mapping of climate risks also based 
on different climate scenarios. Integrate the findings in relevant planning documents and 
construction standards, and into the design of future or renewed energy systems, including 
choices over its  locations.  Greater detail  regarding the financing,  scaling and  timing  of 
adaptation measures to effectively mitigate climate risks should be provided. 

•  Adopt additional measures and policies to reach the LULUCF target and to improve the 
targeting and the commitments of existing interventions such as those under the CAP. 
•  Consider how to enable gradual phaseout of solid fossil fuels in view of the 2032 target of 
the Romanian Decarbonisation Law. Clarify  existing  fossil  fuel  subsidies along  with  a 
detailed timeline for their gradual phase-out. 

•  Consider  adopting  a  more  comprehensive  just  transition  strategy  that  addresses  the 

impact on vulnerable households and allocates sufficient funding. 

•  Put in place robust measures to decarbonise industry, including through renewables-based 
electrification  and  a  supportive  framework  for  CCUS.  Clarify  the  implementation  of 
energy efficiency measures for industry, including a clear financing and investment plan. 
•  Put in place measures to achieve the higher ambition for the deployment of renewables 
by  2030  that  aligns  with  the  EU’s  collective  target  for  renewable  energy.  Identify 
innovative  renewable  energy  technologies  to  be  deployed  by  2030  and  advance  with 
identifying  designated  renewables  acceleration  areas,  including  identifying  which 
renewable energy technologies are to be covered. Reflect on possible measures to promote 
the uptake of renewable power purchase agreements and guarantees of origin.  

•  Apply the “energy efficiency first” principle and adopt specific monitoring mechanisms 
or measures to support implementation. Develop appropriate measures tackling the energy 
consumption  of  the  public  sector  pursuant  to  Articles  5  and  6  EED  recast,  including 
through  the  renovation  of  public  buildings.  Set  the  amount  of  energy  consumption 
reduction to be achieved by all public bodies, disaggregated by sector, as well as the total 
floor area of heated and/or cooled buildings owned by public bodies to be renovated yearly 
or the corresponding yearly energy savings to be achieved.  

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•  Ramp up the pace and depth of renovation in the non-residential building stock and 
expand  the  national  financing  renovation  scheme  to  vulnerable  households  and  people 
affected by energy poverty.  

•  Speed up public procurement processes to successfully implement the energy renovation 

measures in the Recovery and Resilience Plan. 

•  Check  current  plans  to  invest  heavily  in  gas  infrastructure  against  decarbonisation 
objectives.  Romania’s  plan  of  switching  to  at  least  50%  renewable  and/or  low-carbon 
gaseous  fuels  starting  from  2036  may  face  implementation  challenges  due  to  the  slow 
uptake of hydrogen projects in Romania so far. 

•  Streamline  a  framework  for  cooperation  on  cross-border  infrastructure  projects  to 
exploit  the  full  potential  of  regional  cooperation  under  the  CESEC  High-Level  Group. 
Implementation of infrastructure and renewable energy projects as well as completion of 
main CESEC priority regulatory and market actions are essential for enhancing Romania’s 
and regional security of supply. 

•  On  nuclear  energy,  ensure  its  long-term  supply  of  nuclear  materials,  spare  parts  and 

maintenance services. 

•  On transport, reflect on how the targets for electric charging points and for various types 
of alternatively fuelled cars will be achieved for 2030. Consider policies, beyond taxes, 
focusing  on  the  transport  sector  (i.e.  behavioural  measures  targeting  on  a  modal  shift 
towards public transport to reduce energy demand.  

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Slovenia   

1  Overview of key objectives, targets and contributions in the final NECP 

Final updated NECP submitted on 6.12.2024 

Table 1: Summary of key objectives, targets and contributions of Slovenia’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

2022: -9.1% 
2023: -15% 238 

-27% 

NECP:  
-28.6% 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation 
(ESR) (%)  

Binding target for 
additional net GHG 
removals under the 
Regulation on Land 
Use, Land Use Change 
and Forestry 
(LULUCF) 

National 
target/contribution for 
renewable energy: 

Share of energy from 
renewable sources in 
gross final 
consumption of energy 
(%) 

National contribution 
for energy efficiency: 

2022: Reported 
net removals of -
0.17 Mt CO2 eq.  

-0.21 Mt CO2 
eq. (additional 
removal 
target) 

20.4% 
(SHARES) 
17% (target) 

2023: 25.1% 

33% 

Primary energy 
consumption  

7.1 Mtoe 

2023: 5.9 Mtoe 

5.98 Mtoe 

Sufficient 
ambition based on 
projections: An 
overachievement 
of -2.6 Mt CO2 eq 
compared to the 
2030 target 

SI contribution of 
33% is 
signifcantly below 
the 46% required 
according to the 
formula set out in 
Annex II of the 
Governance 
Regulation239 

Sl primary energy 
consumption 
contribution is 
5.98 Mtoe. EED 
recast Annex I 
formula results: 
5.79 Mtoe 
(Reference 
Scenario) or 5.68 
Mtoe (Updated 
Reference 
Scenario). 

238  The ESR emissions in 2022 are based on 2024 final GHG inventory reports, and 2023 emissions are based on 
2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as set out 
in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions for 2021-
2025 will only be established in 2027 after a comprehensive review. 
239 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’). 

211 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
Final energy 
consumption 

5.1 Mtoe 

2023: 4.48 Mtoe 

4.32 Mtoe 

Level of electricity 
interconnectivity 
(%)240 

78.90% 

2024: 85.46% 

15% 

Source: Eurostat; Slovenia’s final updated national energy and climate plan. 

SI final energy 
consumption 
contribution of 
4.32 Mtoe is in 
line with the 
national 
contribution of 
4.32 Mtoe 
submitted by the 
Commission. 

SI surpassess the 
EU-wide 
interconnectivity 
target. 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In  December  2023,  the  Commission  published  a  thorough  assessment  of  Slovenia’s  draft 
updated  NECP  and  provided  recommendations 241 for  the  preparation  of  the  final  updated 
NECP. Slovenia submitted its final updated NECP on 6 December 2024, over five months after 
the deadline of 30 June 2024.242 

2.1  DECARBONISATION 

Based  on  the  projections  available  in  the  NECP,  Slovenia  expects  to  decrease  total  GHG 
emissions (including LULUCF and excluding international aviation) by 22% in 2030 and by 
75% in 2040 compared to 1990. The NECP does not include emission projections from 2040 
to 2050. Slovenia has a target of climate-neutrality by 2050 in law.  

2.1.1  Effort Sharing Regulation 
Slovenia has addressed recommendation 1. The final NECP provides sufficient information 
on  how  Slovenia  will  meet  its  ESR  target  of  -27%  by  2030  compared  to  2005.  The  plan 
provides updated projections that are similar to the draft plan, showing that the existing and 
planned policies and measures will lead to  a decrease of 28.6% in 2030 compared to 2005, 
overachieving the national ESR target by 1.6 percentage points. In 2023, GHG emissions from 
ESR sectors represented around 69% of the total in Slovenia and are expected to be around 
66% in 2030.243 The ‘with additional measures’ (WAM) projected value in 2030 is around 19 
percentage points lower than the 9.5% reduction projection under the ‘with existing measures’ 
(WEM) scenario, hinting that implementing the plan will require a significant effort. 

The  final  plan  complemented  the  information  on  the  policies  and  measures  provided  in  the 
draft but more details on scope, timeline and expected impact on GHG emissions would be 

240  Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2024). The 2030 level 
represents the general interconnectivity target of 15%. 
241 SWD (2023) 924 final, and Commission Recommendation of 18 December 2023, C/2023/9614. 
242 Article 14(2) Governance Regulation. 
243 The  2023  emissions  are  based  on  2024  approximated  inventory  reports  and  2030  is  based  on  reporting  of 
greenhouse gas projections (Article 18 of the Governance Regulation). 

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useful. This is particularly the case for transport, which accounted for around 50% of all ESR 
emissions in 2022 and is projected in 2030 to also dominate ESR emissions, decreasing by only 
1% in the ‘with additional measures’ (WAM) scenario and increasing by over 40% in the ‘with 
existing measures’ (WEM) scenario.244 Slovenia’s measures to address the continued growth 
of  road  (freight  and  passenger)  transport  focus  on  upgrading  existing  rail  infrastructure, 
developing  integrated  public  transport,  and  promoting  sustainable  mobility  by  developing 
cycling, walking, and recharging infrastructure.  

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings,  road  transport  and  additional  sectors  (ETS2).  The  scenario  projections  do  not 
account for the effect of ETS2, and do not clearly consider the impact of ETS2 in achieving 
the ESR target. 

2.1.2  LULUCF 
Slovenia  has  partially  addressed  recommendation  3.  The  LULUCF  sector  in  Slovenia 
generates net removals, absorbing roughly 1% of the total GHG emissions in 2022. According 
to the LULUCF Regulation, Slovenia has to improve its net removals by -0.21 Mt CO2eq in 
2030 as compared to its yearly average in the 2016-2018 reference period. According to the 
latest  reported  2022  figures,  Slovenia’s  performance  has  improved  by  -  0.91  Mt  CO2eq  in 
comparison  to  the  reference  period.  Taking  into  account  its  projections  for  2030,  Slovenia 
projects an overachievement of -2.6 Mt CO2eq in 2030. The plan indicates additional policies 
for LULUCF compared to the baseline scenario.  

However, the plan does not provide sufficient information on how public funding (including 
CAP, state aid) and private financing through carbon farming schemes are used to reach the 
LULUCF target. Similarly, it does not set out information as to how specific measures will 
contribute to the national LULUCF target. The plan also 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. 

2.1.3  Carbon Capture and Storage 
Slovenia  has  not  addressed  recommendation  2.  The  plan  does  not  provide  a  detailed 
breakdown of the potential annual CO2 emissions that could be captured by 2030. The plan 
does  not  offer  information  on  the  development  of  CO2  transport  infrastructure  or  storage 
capacity. Slovenia has a ban on CO2 storage, so the plan indicates there are no plans to capture 
CO2 at scale by 2030. However, the plan reports that financial incentives for CCUS in hard-to-
abate sectors are to be developed, aiming to encourage pilot project in the cement industry. 

2.1.4  Adaptation 
Slovenia  has  partially  addressed  recommendation  4.  The  plan  refers  to  the  country’s 
national  adaptation  plan  ‘Strategic  Framework  on  Climate  Adaptation’  to  respond  to  the 
recommendation, acknowledging the importance of integrating adaptation planning. The plan 
is rather comprehensive and embeds adaptation policies and measures in the relevant Energy 
Union dimensions.  The plan contains a partial analysis of climate vulnerabilities and risks. 

244 Based on Table 64 in the NECP. 

213 

 
 
 
 
 
 
.  The  plan  also  mentions  briefly  the  need  to  prioritise  nature-based  solutions  but  does  not 
provide information on the funding needed for their deployment.  

The plan partially outlines the link to the specific Energy Union objectives and policies, that 
adaptation  policies and  measures  are meant  to  support,  particularly  for research, innovation 
and competitiveness. However, the impacts and benefits of adaptation policies on other Energy 
Union  objective  have  generally  not  been  quantified.  The  plan  sets  out  some  additional 
adaptation policies and measures to support the achievement of national objectives, targets 
and contributions under the Energy Union.  Measures proposed in the field of agriculture are 
nevertheless  limited  to  monitoring.  The  land  use,  land  use  change  and  forestry  (LULUCF) 
sector  Slovenia  is  adjusting  the  tree  composition  and  structure  of  forests  to  the  impacts  of 
climate change. 

2.1.5  Fossil Fuels 
Slovenia  has  not  addressed  recommendation  19.  The  plan  mentions  the  commitment  to 
phase out of fossil fuel subsidies, also indicating some amounts paid as energy subsidies in the 
past. However, the plan does not set a clear roadmap for phasing out fossil fuel subsidies. 

2.2  RENEWABLES  

Slovenia  has  partially  addressed  recommendation  5.  The  plan  includes  an  updated 
contribution of 33% of renewables in gross final energy consumption by 2030 which remains 
significantly below the level of 46% resulting from the formula in Annex II of the Governance 
Regulation  and  recommended  by  the  Commission245.  The  updated  indicative  trajectory  for 
achieving  its  contribution  of  33%  by  2030  has  been  provided  including  specific  reference 
points for 2025 (28.4%) and 2027 (30.2%), which are below the trajectory calculated in line 
with the increased EU 2030 renewable energy target of 42.5% (34% and 39% respectively)246.   

Slovenia  has  partially  addressed  recommendation  6.  The  plan  provides  estimated 
trajectories for the deployment of renewable energy technologies over the next 10 years, with 
an outlook to 2040. Slovenia aims to install 5% of innovative renewable energy technologies 
in line with Directive (EU) 2018/2001 (the ‘revised RED II’)247. The plan also includes specific 
targets namely an average annual increase of 2.5pp for district heating and cooling by 2030 
covering between 25%- 40% by waste heat, a renewable energy share of 30% in industry by 
2030 including use of waste heat. The plan includes a binding minimum of 42% of renewables 
of non-biological origin in industry in 2030, a share of renewable energy of 55% in buildings, 
45% in heating and cooling and 26% for transport by 2030.  The share of renewable energy in 
heating and cooling falls short of the required 0.8pp increase per year on average in the period 
2021- 2025 but is above the required 1.1 pp in 2026-2030.  

245 The draft updated Plan includes the share of renewable energy share as a range between 30 and 35% in gross 
final energy consumption in 2030. 
246 The justification provided is the high risk of conflict with other objectives of Slovenia or the EU, especially in 
the area of biodiversity. 
247 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  

214 

 
 
 
 
 
 
Slovenia has partially addressed recommendation 7. Slovenia plans to designate renewable 
acceleration  areas  through  the  preparation  of  a  Thematic  Action  Programme  for  potential 
priority areas for the solar and wind energy, without providing further details on it. The plan 
includes measures to promote the renewable and energy communities, self-consumption, the 
uptake  of  guarantees  of  origin,  and  the  power  purchase  agreements.  The  plan  describes 
measures to promote renewable hydrogen use in the industry sector but does not explain how 
Slovenia prepares for renewable hydrogen trade. Slovenia aims to introduce several measures 
for  the  deployment  of  renewables  in  view  of  phasing  out  of  fossil  fuels  in  the  heating  and 
cooling sector Slovenia plans to develop a heating and cooling strategy for 2050 with an action 
plan (in 2025) with a particular focus on the efficient use of electricity in heating and cooling.  

Slovenia partially addressed recommendation 8. The final NECP includes some projections 
for the use of woody biomass per sector. Slovenia has not included any detailed data on imports 
and the source of forest biomass used for energy. It explained, however, that it does not expect 
any  significant  imports of  woody  biomass  for  energy.  The  plan  does  not  include  a  detailed 
assessment of the compatibility of the projected use of forest biomass for energy production 
with Slovenia’s obligations under the revised LULUCF Regulation. The final plan notes that 
the use of woody biomass is aligned with LULUCF objectives and does not reduce sinks, but 
it reduces the need for other energy sources. It also notes that the total use of woody biomass 
for energy purposes is projected to decrease by 2030. On biomethane Slovenia provides limited 
measures to support sustainable biogas and biomethane production. 

Slovenia  has  addressed  recommendation  9  as  the  final  NECP  includes  details  on  the 
procedural steps and timelines for the transposition and implementation of the provisions of 
the revised RED II.  

2.3  ENERGY EFFICIENCY DIMENSION 

Slovenia  has  partially  addressed  recommendation  10.  Slovenia  includes  an  indicative 
national contribution of 4.3 Mtoe for final energy consumption to the Union’s binding final 
energy consumption target for 2030 1. This contribution is in line with Article 4 of Directive 
(EU) 2023/1791 (‘EED recast’)248, or equal to the corrected indicative national contribution 
that the Commission submitted to Slovenia in March 2024 under Article 4(5) of EED recast. 
Slovenia included an indicative national contribution to the Union’s indicative primary energy 
consumption target for 2030 of 6.0 Mtoe for primary energy consumption. This contribution is 
not in line with Article 4 of EED Recast. There is still a gap of 3.3% compared to the target 
calculated with respect to the indicative results of the 2020 reference scenario, and a gap of 
5.4% compared to the target calculated with respect to the indicative results of the updated 
2020 reference scenario. 

Slovenia has not included the amount of energy consumption reduction per year to be 
achieved  by  all  public  bodies.  Slovenia  does  not  report  the  total  floor  area  of  heated  and 
cooled buildings owned by public bodies to be renovated yearly - nor the corresponding yearly 
energy savings to be achieved as required by Article 6 of EED Recast. The plan does not specify 

248 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 

215 

 
 
 
 
 
 
if Slovenia opted for alternative or default approach2. Slovenia sets out policies and measures 
to achieve the reduction of energy consumption from public bodies and the renovation of public 
buildings,  such  as  the  promotion  of  energy  management  system  and  a  programme  to 
progressively  phase out  the use of fossil fuels.  Slovenia includes the amount  of cumulative 
energy  savings  of  3.1  Mtoe3  to  be  achieved  over  the  period  from  1  January  2021  to  31 
December 2030 in line with Article 8 of EED Recast and included an explanation on how the 
annual savings rate and the calculation baseline were established. 

Slovenia  has  partially  addressed  recommendation  11.  The  plan  sets  out  policies  and 
measures  to  achieve  the  national  contributions  on  energy  efficiency  as  well  as  the  required 
amount of end-use energy savings, but it does not quantify the expected energy savings nor the 
contribution for each of the reported energy efficiency measures. However, Slovenia provided 
the quantification of the savings from the energy efficiency measures targeting energy poverty. 
The  plan  explains  how  the  energy  efficiency  first  principle  will  be  implemented  and 
mentioned  one  measure  relevant  for  its  implementation  and  monitoring.  Slovenia  specifies 
robust  energy  efficiency  financing  programmes  and  support  schemes,  including  financial 
instruments  and  public  guarantees,  able  to  mobilise  private  investments  and  additional  co-
financing.  The  plan  describes  existing  policy  measures  to  promote  the  uptake  of  energy 
efficiency lending products and innovative financing schemes (such as Energy Performance 
Contracts).  Slovenia  sets  out  adequate  measures  to  promote  energy  audits  and  energy 
management system.  

Slovenia  has  not  address  recommendation  12.  The  plan  includes  a  list  of  policies  and 
measures  related  to  building  renovations.  However,  it  did  not  update  the  2020  Long-Term 
Renovation Strategy’s ambition in terms of energy savings. Slovenia did not detail the impact 
in terms of energy savings of each new measure put forward. Slovenia indicated the new and 
updated milestones will be provided in the future National Building Renovation Plan. 

2.4  ENERGY SECURITY DIMENSION 

Slovenia  has  partially  addressed  recommendation  13.  In  terms  of  diversifying  energy 
sources, it notably refers to an intention to reinforce cross-border capacities to promote security 
of gas supply, yet there are only few details on measures, timeline or performance indicators. 
While the plan clarifies that the bulk of Russian gas supplies were already phased out and that 
there is no longer an active contract between Slovenian suppliers and the Russian federation, 
the plan also notes that the share of Russian gas in Slovenian gas imports can range from 0 to 
30%.  Lastly,  while  the  plan  does  not  provide  projections  on  the  evolution  of  primary 
consumption of fossil gas as such, it does so for gaseous fuels: it is expected to decrease from 
24 TWh in 2021 to 19 TWh by 2030. 

Diversification of generation and supply continues to be a key priority. In particular, the final 
plan notably highlights the overachievement of the 15% electricity interconnection target (over 
80% today) as an important contribution to the security of electricity supply. Slovenia even 
intends  to  bring  this  rate  to  85%  by  2030.  While  the  plan  defines  general  objectives  for 
developing energy storage, these are not quantified.   

The plan does not assess the adequacy of the oil infrastructure (pipelines, oil stocks) in the long 
run with the expected oil demand decline and the move to lower-carbon alternatives.    

216 

 
 
 
 
 
The final plan adds a new climate vulnerability analysis and includes an explicit reference to 
the need to assess such vulnerabilities in the section on energy security. Nevertheless, the plan 
contains few new concrete measures and objectives beyond the objective to increase the share 
of underground distribution grid to 50% (from 35% currently) to increase resilience against 
extreme weather events. 

As regards nuclear energy, the plan confirms that Slovenia aims to maintain the operation of 
the Krško nuclear power plant and to decide on the construction of a new nuclear power plant 
no later than in 2028. One of the scenarios envisages the installation of a new conventional 
nuclear power plant by 2040 and the construction of a small modular nuclear reactor by 2050. 
The  plan  does  not  address  the  issues  of  diversification  and  security  of  supply  of  nuclear 
materials, fuel, spare parts, and services. 

Regarding  nuclear  waste,  the  plan  indicates  that  Slovenia  has  adopted  a  Resolution  on  the 
National Programme for Radioactive Waste and Spent Fuel Management 2023-2032. It aims 
to ensure that the financial resources needed to achieve the objectives of the decommissioning 
and disposal programme for low- and intermediate-level waste and spent fuel are adequately 
collected. 

2.5  INTERNAL ENERGY MARKET DIMENSION 

Slovenia has partially addressed recommendation 14. The plan provides clear targets and 
objectives to improve the flexibility of the energy system by defining specific measures and 
deadlines for demand response, storage, and system  flexibility.  However, the plan does not 
elaborate  on  the  quantification  of  flexibility  needs.  The  plan  includes  incentives  for 
development  of  local  storage  with  renewable  energy  and  advanced  flexibility  devices  with 
further measures like advanced metering systems and RES-storage incentives planned by 2030. 
The  plan  aims  to  develop  policies  and  measures  that  enhance  flexibility  and  enable  a  non-
discriminatory participation of new flexibility services to the market. Some of these measures 
include supporting a functional flexibility market and targeting full system flexibility to meet 
100% of the frequency restoration reserve (RPF) through market-based services by 2030. Even 
though the plan includes several measures aimed at facilitating energy system integration, it 
does  not  elaborate  on  specific  measures  in  the  context  of  implementing  Article  20a  of  the 
revised RED II.  

The  plan  includes  measures  for  stakeholder  engagement  and  active  customers  in  order  to 
strengthen consumer empowerment in the retail market. It also foresees incentives to invest in 
advanced customer devices and coordination mechanisms to improve market flexibility, as well 
as  measures  to  promote  local  energy  communities  and  renewable  energy  communities  and 
energy sharing schemes. It however includes little information on measures to simplify supply 
offers to customers and details on their comparability.   

Slovenia has  partially addressed  recommendation  15.  The  plan  includes  clear  targets  on 
energy  poverty  alleviation  and  investments  in  energy  efficiency  and  renewable  sources  in 
households in energy poverty. It also includes a new target on cumulative energy savings to be 
achieved  in  households  in  energy  poverty.  The  Energy  Poverty  Action  Plan  was  better 
described, although it still lacks details on the pilot phase (2024-2026) and the implementation 
of  the  long-term  financing  of  the  operation  of  the  scheme.  The  ’Strategic  Energy  Poverty 
Council’ that was mentioned in the draft NECP became the ‘Energy Poverty Panel’ in the final 

217 

 
 
 
 
 
 
NECP. The additional details provided foresee a coordinated role of the panel in the first phase, 
and a steering role at a later stage, with no further specifications. Measure 31.3 provides more 
insights on the implementation of actions to alleviate energy poverty. However, the focus on 
local level could have been enhanced. 

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Slovenia has partially addressed recommendation 16. The plan provides a comprehensive 
approach,  including  targets  to  support  research,  innovation,  and  competitiveness  in  clean 
energy technologies, establishing a pathway to 2030, but not to 2050. Significant policies and 
measures include an increase in R&D investment – at least 3.5% of GDP by 2030, planned 
increased  cybersecurity  in  all  strategic  systems,  support  to  the  upgrade  and  deployment  of 
research  infrastructure  (including  energy  storage  technologies,  energy  sites  and  research 
nuclear infrastructures). Nevertheless, the plan fails to provide details on the presented policies 
and measures for the digitalisation of the energy system.  

The plan does not set out measures to promote the development of net-zero projects, including 
those  relevant  for  the  energy  intensive  industries,  but  lists  actions  related  to  funding  and 
monitoring  for  demonstration  projects  for  the  green  transition.  It  does  not  describe  how 
Slovenia  will  ensure  a  predictable  and  simplified  regulatory  framework  for  permitting 
procedures for manufacturing but includes information on how access to national funding will 
be simplified where needed (developing long-term research programme to support the green 
transition). The plan includes  information  on policies and measures  for the development  of 
clean energy-related skills (training for energy efficiency, RES, and green technologies) but 
does not include information on how to facilitate resilient and sustainable supply chains of key 
net-zero components and equipment.  

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Slovenia addressed recommendation 17. The plan provides estimates of the investment needs 
per sector, with a breakdown for private and public investments. Though investment needs are 
not presented at the level of initiatives, the plan provides estimates of the investment gaps. The 
plan states that substantial private investments will be needed but does not specify the measures 
and initiatives specifically aimed at mobilising private capital. Funding sources (both national 
and EU) are presented in an aggregate form, but not at the level of the initiatives.  

Slovenia  has  addressed  the  recommendation  to  provide  a  robust  assessment  of  the 
macroeconomic impact of the planned policies and measures. The methodology employed 
is  detailed  in  reference  documents.  The  macro-economic  assessment  in  these  documents  is 
well-founded. 

2.8  JUST TRANSITION 

Slovenia has partially addressed recommendation 20. The plan provides some information 
on  the  impact  of  the  transition  to  climate  neutrality  on  employment  and  skills  but  lacks  a 
granular assessment. The plan does not specify the form of support, the impact of initiatives or 
the resources available, except for the Just Transition Fund. 

218 

 
 
 
 
 
The plan lacks the analytical basis needed for the preparation of the Social Climate Plan, such 
as information on the estimated impact of ETS2 and the identification of vulnerable groups. 
The plan does not explain how the policy framework identified in the NECP will contribute to 
the preparation of Slovenia’s Social Climate Plan nor how the consistency of the two plans will 
be ensured.  

2.9  PUBLIC CONSULTATION 

Slovenia has partially addressed recommendation 21. The plan includes detailed summaries 
of the outcome of the consultation, but without substance relating to the public’s views. It does 
not  include  any  details  on  the  resulting  changes  to  the  final  NECP  or  summaries  of  or 
explanations as to why certain suggested changes could not be addressed. 

2.10 REGIONAL COOPERATION 

Slovenia has partially addressed  recommendation 22.  The plan does  not  emphasise how 
Slovenia plans to coordinate and realise regional priority actions that concern Slovenia and are 
relevant for Central-Eastern and South-Eastern European regions. The plan includes a measure 
to  incentivise  cross-border  and  regional  cooperation  on  renewable  energy  projects,  by 
establishing  a  framework  for  cooperation  with  other  Member  States  by  2025,  in  line  with 
Article 9 of the revised RED II. 

The plan provides some information on the signature of bilateral solidarity agreements with its 
neighbours  in  the  annex.  Slovenia  indicates  that  there  are  no  plans  for  an  agreement  with 
Austria and to rather rely on the newly established default solidarity rules, and that talks are 
ongoing with Hungary.   

2.11 ANALYTICAL BASIS 

The plan provides an analytical framework with projections reaching 2050, based on the REES-
SLO  model,  an  adaptation  of  the  REES  framework  for  Slovenia.  Slovenia  also  provided  a 
macro-economic  impact  assessment  of  different  scenarios  (in  a  separate  document). 
Nevertheless,  further  integration  with  the  sensitivity  analysis  and  stress  testing  of  the  key 
variables could enhance the analysis of potential implications and uncertainties associated with 
the different policy pathways. 

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

Slovenia has partially addressed recommendation 18. The plan does not outline some of the 
main reforms and investments of the Recovery and Resilience Plan (RRP) that contribute to 
implementing the objectives, targets and contributions of the Energy Union. While the plan 
outlines the foreseen resources in the RRP, including its REPowerEU chapter, for the green 
transition, these are not linked to specific investments. Furthermore, the plan does not outline 
key reforms under the RRP and its REPowerEU chapter linked to the deployment of renewable 
energy installations and of alternative fuels infrastructure. 

219 

 
 
 
 
 
3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

The Commission encourages Slovenia to ensure a timely and complete implementation of the 
final  updated  NECP.  Slovenia  is  invited  to  pay  particular  attention  to  the  following  main 
elements:  

• 

Implement in a timely manner additional policies towards the ESR target, notably in the 
transport sector as a very significant part of the emissions reduction is driven by measures 
that are not yet fully in place.   

•  Closely monitor the implementation of relevant policies and measures on the evolution of 

the LULUCF sector to ensure it reaches its 2030 target.   

•  On  adaptation,  assess  quantitatively  climate  vulnerabilities  and  risks  regarding  the 
achievement  of  the  national  objectives,  targets,  and  contributions  and  the  policies  and 
measures in the different Energy Union dimensions. That would enable better outlining 
and  quantifying  the  link  to  the  specific  Energy  Union  objectives  and  policies,  that 
adaptation policies and measures are meant to support, as well as setting out additional 
adaptation policies and measures in sufficient detail.  

•  Clarify existing fossil fuel subsidies along with a detailed timeline for their gradual phase-

out. 

•  As regards renewable energy, put in place measures to achieve the higher ambition for 
the  deployment  of  renewables,  including  wind,  by  2030  that  aligns  with  the  EU’s 
collective  target  for  renewable  energy.  Ensure  a  swift  and  timely  transposition  of  the 
revised RED II to support the objectives of the updated NECP. Increase the average annual 
renewable energy share in heating and cooling in line with the binding sub-target and 
the indicative top-up of Article 23 of the revised RED II. In addition, swiftly implement 
the planned reforms to speed-up permit-granting and administrative procedures for the 
deployment of renewables in line with the revised RED II, including by enhancing internal 
coordination allowing simultaneous permitting applications and increasing financial and 
especially  human  resources  available  to  public  authorities.  In  this  regard,  it  is  key  to 
complete  the  development  of  the Thematic Action  Programme  for  identifying  potential 
priority areas for solar and wind power in line with Article 15c of the revised RED II by 
February 2026. 

•  Consider adopting an overall electrification strategy at national level to coordinate and 
have  a  better  overview  on  planned  electrification  efforts,  including  for  instance  by 
improving  grid  connection  waiting  times  in  the  solar  sector  and  accessibility  for 
individuals who want to invest in self-supply using renewable energy sources. Ensuring 
overall energy system integration in line with the provisions contained in Article 20a of 
the revised RED II. 

•  Consider adopting a strategy to increase wind power capacity including considering the 
role  of  local  communities  and  alternative  dispute  resolution  systems  to  enhance  public 
acceptability, ensuring environmental and climate risk assessments are in place, exploring 
synergies  with  biodiversity  objectives,  and  setting  up  auctions  to  support  the  uptake  of 
renewable energy, together with a clear project pipeline.     

•  On  nuclear  energy,  ensure  its  long-term  supply  of  nuclear  materials,  spare  parts  and 

maintenance services. 

220 

 
 
 
 
 
•  Regarding  energy  efficiency,  put  in  place  measures  to  achieve  the  higher  ambition  for 
energy  efficiency  by  2030  for  primary  energy  consumption  and  further  expand  energy 
efficiency measures targeting the public sector.  

•  On  industry,  set  up  additional  measures  to  the  existing  financial  incentives  for  energy 
audits and the promotion of renewable energy as industry is projected to be the second 
most-consuming  sector  in  2030.  Consider  further  measures  to  support  new  low  carbon 
technologies including hydrogen and the promotion of circular economy. 

•  Develop a comprehensive just transition strategy which takes into account the impact on 

vulnerable groups. 

221 

 
 
 
 
 
 
 
 
Finland 

1  Overview of key objectives, targets and contributions in the final NECP 

Table 1: Summary of key objectives, targets and contributions of Finland’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 
national 
targets and 
contributio
ns 

2022: -22.9% 
2023: -27%249 

-50% 

Reported net 
emissionsof 
4.44 Mt CO2 eq. 
in 2022 

-2.89 Mt 
CO2 eq. 
(additional 
removal 
target) 

Assessment of 
2030 ambition 
level 

NECP:  
-45.2% 
However, FI is 
expected to 
meet the 2030 
target with ESR 
flexibilities 

Insufficient 
ambition based 
on projections: 
a gap of 1.22 Mt 
CO2 eq 
compared to the 
2030 target 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for net 
GHG removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 
Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

43.9% 
(SHARES) 

38% (target) 

2022: 47.7%  

2023: 50.7% 

National contribution for 
energy efficiency: 

62% gross final 
consumption of 
energy  

Finland’s 
contribution of 
62% is in line with 
the contribution 
according to the 
formula set out in 
Annex II of the 
Governance 
Regulation250 

Primary energy 
consumption  

35.9 Mtoe 

2023: 31.3 Mtoe 

n.a. Mtoe251 

Finland did not 
provide a 
primary energy 
consumption 
contribution. 

249  The ESR emissions in 2022 are based on 2024 final GHG inventory reports, and 2023 emissions are based 
on 2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as set 
out in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions for 
2021-2025 will only be established in 2027 after a comprehensive review. 
250 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’). 
251 Strictly, the final NECP states that Finland’s national energy and climate strategy will be completed in spring 
2025. Finland provided values for a WEM scenario instead, which would contribute 30.7 Mtoe primary energy 
consumption.  

222 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EED recast 
Annex I formula 
results: 29,8 
Mtoe 
(Reference 
Scenario) or 
29.7 Mtoe 
(Updated 
Reference 
Scenario). 

Finland did not 
provide a final 
energy 
consumption 
contribution. A 
national 
contribution of  
20.6 Mtoe was 
submitted by the 
Commission. 

FI has surpased 
EU-wide 
interconnectivit
y target 

Final energy consumption 

26.7 Mtoe 

2023: 22.2 Mtoe 

n.a.252 

Level of electricity 
interconnectivity (%)253 

29.0% 

2024: 15.5% 

15% 

Source: Eurostat; Finland final updated national energy and climate plan 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In  December  2023,  the  Commission  published  a  thorough  assessment  of  Finland’s  draft 
updated  NECP  and  provided  recommendations 254 for  the  preparation  of  the  final  updated 
NECP. Finland submitted its final updated NECP on 28 June 2024, in line with the deadline of 
30 June 2024.255 

2.1  DECARBONISATION 

Based on the projections available in the plan, Finland expects to decrease total GHG emissions 
(including LULUCF and excluding international aviation) by 51% in 2030, by 71% by 2040 
and  by  90%  by  2050  compared  to  1990.  These  projections  are  based  on  a  ‘with  existing 
measures’ (WEM) scenario and do not reflect additional measures.  

252 Strictly, the final NECP mentions a contribution of 20.6 Mtoe but  states that Finland’s national energy and 
climate strategy will be completed in spring 2025. Finland provided values for a WEM scenario instead, which 
would contribute 22.8 Mtoe final energy consumption.  
253  Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2024).  The 2020 
figure also covers interconnectors with the neighbouring countries outside the EU. The 2030 level represents the 
general interconnectivity target of 15%. 
254 SWD(2023) 914 final, and Commission Recommendation of 18 December 2023, C/2023/9604. 
255 Article 14(2) of Governance Regulation. 

223 

 
 
 
 
 
 
 
 
 
2.1.1  Effort Sharing Regulation 
Finland has partially addressed recommendation 1. The final NECP provides some details 
on how Finland will meet its ESR target of -50% by 2030 compared to 2005. 

The plan provides only projections in the ‘with existing measures’ (WEM) scenario, showing 
a decrease of 45.2% in 2030 compared to 2005, a gap of 4.8 percentage points compared to the 
national ESR target. In 2023, GHG emissions from ESR sectors represented 62% of the total 
in Finland (expected to be 72% in 2030)256, with transport accounting for the largest, followed 
by  agriculture.  Finland  is  expected  to  achieve  its  ESR  target  with  the  use  of  flexibilities. 
However,  Finland  has  accounting  debit  gaps  under  the  LULUCF  Regulation,  which  are 
projected  to  impact  its  performance  under  the  ESR.  The  plan  partially  complemented  the 
information on policies and measures provided in the draft but the description of their scope, 
timeline and GHG reduction impact is only partial. 

On  transport,  the  plan  aims  at  halving  emissions  by  2030  compared  to  2005  by  replacing 
fossil  fuels  with  alternative  fuels,  by  renewing  the  vehicle  fleet  and  enhancing  energy 
efficiency. However, the support schemes to purchase natural gas (heavy-duty) vehicles – and 
for the use of natural gas in transport, risk undermining the target unless covered entirely with 
biogas.  

Emissions from waste management have decreased steadily but national measures to reduce 
emissions from waste incineration have not been implemented. Several measures in the plan 
are likely to contribute to a reduction in GHG emissions from agriculture, the largest source 
of methane emissions in Finland, but the magnitude remains difficult to estimate. The plan also 
contains measures to further reduce F-gas emissions efficiently. 

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings,  road  transport  and  additional  sectors  (ETS2).  The  scenario  projections  do  not 
account for the effect of ETS2, and do not clearly quantify its impact in achieving the ESR 
target.  

2.1.2  LULUCF 
Finland  has  partially  addressed  recommendation  3.  The  LULUCF  represent  10%  of  the 
total GHG emissions in Finland in 2022. The latest reported 2022 figures show that Finland 
worsened its performance by 9.1 Mt CO2eq compared to its yearly average in the 2016-2018 
reference  period.  According  to  the  LULUCF  Regulation,  Finland  has  to  enhance  its  net 
removals by -2.89 Mt CO2eq in 2030 as compared to the reference period.  Taking into account 
its projections for 2030, Finland will still have a gap of 1.22 Mt CO2eq in 2030. This gap could 
affect the achievement of the ESR target.  

The main driver behind the worsening performance of LULUCF sector, currently a net source 
of emissions, is the increase of commercial loggings combined with a slower growth in forests. 
Furthermore, the lack of action for reducing emissions from organic soils, which is the main 
source of LULUCF emissions, has a big influence in the overall results. 

The plan indicates that for LULUCF there are no additional policies compared to the baseline 
scenario. Nonetheless, the plan mentions several policies, including a Climate Plan for the Land 
Use Sector, prepared in 2022 and updated in 2024. According to this plan, Finland will reach 

256 The 2023 emissions are based on 2024 approximated inventory reports. 

224 

 
 
 
 
 
 
additional  net  removals  of  2  Mt  CO2eq  in  2030  and  hence  comply  with  the  2030  target. 
Although these are steps in the right direction, the final measures are still under preparation at 
the time of submitting the NECP and therefore cannot yet be assessed.  

The plan does not provide sufficient information on how public funding (CAP, state aid) and 
private financing through carbon farming schemes are used to reach the LULUCF target. The 
draft  also  lacks  information  on  the  status  and  progress  in  ensuring  higher  tier  levels  and 
geographically explicit datasets needed to guarantee the robustness of net removal estimates. 

2.1.3  Carbon Capture and Storage 
Finland has not addressed recommendation 2. The plan does not identify the amount of CO2 
emissions that can be captured by 2030. It mentions that no geological storage sites have been 
identified in Finland and that there are no large fossil CO2 point sources suitable for capture. 
Biogenic sources could be an option, though due to need to develop transport infrastructure to 
a harbour for transport by ship, CCU is considered as a better option.  

2.1.4  Adaptation 
Finland has partially addressed recommendation 5. The plan refers to the National Climate 
Change Adaptation Plan until 2030 (NAP2030), acknowledging the importance of integrating 
adaptation  planning.  It  embeds  adaptation  policies  and  measures  in  the  Energy  Union 
dimensions.   

The plan partially outlines the links to the specific Energy Union objectives and policies that 
adaptation  policies  and  measures  are  meant  to  support,  particularly  for  the  energy  security 
dimension. It outlines several nature-based solutions, including peatland restoration, wetland 
creation, and sustainable forest management, aimed at enhancing carbon sinks and improving 
climate resilience. These measures are expected to reduce emissions, improve water retention, 
prevent  floods,  and  enhance  biodiversity,  contributing  significantly  to  climate  adaptation 
efforts.  However,  the  impacts  and  benefits  of  adaptation  policies  on  other  Energy  Union 
objectives have generally not been quantified.  

Finland has provided further clarification on their overall approach to adaptation policy, with 
streamlining in sectoral and local planning, and in other national plans.   

2.1.5  Fossil Fuels 
Finland has partially addressed recommendation 20. The plan mentions the Territorial Just 
Transition Plans (TJTPs) commitment to reduce peat use by 50% by 2030 but does not explain 
how to achieve this target nor the necessary measures and resources to support the peat phase-
out. The plan does not sufficiently explain the alignment between the TJTPs and NECP.  

The plan indicates that there are no clear fossil fuel subsidies nor established definitions for 
them257. Nonetheless, it lists some fossil fuel subsidies, such as tax reductions or exemptions 
for natural gas and diesel used in transport, for which no phase-out is foreseen. 

257 The Commission 2024 study and  Report on Energy subsidies in the EU identify the existence of fossil fuel 
subsidies. 

225 

 
 
 
 
 
 
2.2  RENEWABLES  

Finland has addressed recommendation 6. The plan includes an increased contribution of 
the renewable energy share to 62% in gross final energy consumption by 2030, which is in line 
with  the  level  resulting  from  the  formula  in  Annex  II  of  the  Governance  Regulation.  The 
updated trajectory for achieving the contribution is also provided, with the specific reference 
points of 49% for 2025 and 54% for 2027 respectively also included, which correspond to the 
trajectory calculated in line with the increased EU 2030 renewable energy target of 42.5%.  

Finland  has  partially  addressed  recommendation  7.  The  plan  provides  information  on 
projections for offshore wind beyond 2030, with an outlook up to 2050. Finland indicates that 
it  endeavours  to  reach  an  indicative  target  5%  of  innovative  renewable  energy  for  newly 
installed  renewable  energy  capacity  by  2030.  Finland  also  aims  to  increase  the  share  of 
renewable energy in the industry sector by 1.6 pp annually until 2030 including referring to the 
specific target of renewable fuels of non-biological origin (RFNBOs) for industry (stating that 
the achievement of RFNBO targets in 2030 and 2035 is highly dependent on new investments 
that are under development).  However, the plan does not include a specific target in buildings 
to contribute to the sectoral target, even though the 85% of renewable share and waste heat in 
2030 indicates a target would most likely be reached. Finland sets out a combined target for 
advanced  biofuels  and  RFNBOs  in  transport  stating  that  the  minimum  binding  level  for 
RFNBOs in transport will be reached (29% in 2030).  

Finland  has  partially  addressed  recommendations  8  and  10.  Regarding  the  RFNBO  in 
industry, the plan mentions ongoing projects (planning phase or under construction) and points 
out that Finland is currently assessing the need for additional measures to use RFNBOs to reach 
the target, such as new legislation which will be implemented in May 2025 together with other 
measures required by Directive (EU) 2018/2001 (the ‘revised RED II’)258. 

On permitting, speeding up permitting processes and predictability in governmental procedures 
are mentioned as principal elements to strengthening competitiveness in Finland. However, the 
plan does not describe how Finland plans to designate the renewables acceleration areas. The 
uptake  of  power  purchase  agreements  is  well  outlined,  in  particular  concerning  new  wind 
power projects. The final plan also provides additional information on measures to promote 
self-consumption and renewable energy communities. The plan lacks details on the procedural 
steps and timelines for most policies and measures in particular on industry-related measures 
notably  RFNBOs  and  on  guarantees  of  origin.  Finland  includes  measures  to  promote  the 
sustainable production of biomethane.   

Finland has addressed recommendation 9. The plan provides projections on biomass by type 
used for 2020-2030. It also provides some information on the compatibility of the projected 
use  of  forest  biomass  for  energy  production  with  Finland’s  obligations  under  the  revised 
LULUCF  Regulation.  Finally,  Finland  includes  measures  to  promote  the  sustainable 
production of biogas, but does not quantify the target, feedstock to be used and the market for 
resulting byproducts. 

258 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  

226 

 
 
 
 
 
 
2.3  ENERGY EFFICIENCY DIMENSION  

Finland  has  not  addressed  recommendation  11.  Finland  did  not  include259 an  indicative 
national contribution to the Union’s binding final energy consumption target for 2030 for final 
energy  consumption 260  nor  an  indicative  national  contribution  to  the  Union’s  indicative 
primary energy consumption target for primary energy consumption261.  

Finland  included  the  amount  of  energy  consumption  reduction  of  11.9  ktoe  per  year  to  be 
achieved by all public bodies, which is also disaggregated by sector, but Finland did not report 
the total  floor area of heated and  cooled buildings owned by public bodies to  be renovated 
yearly, nor the corresponding yearly energy savings to be achieved262. Finland did not set out 
policies  and  measures  neither  to  achieve  the  reduction  of  energy  consumption  from  public 
bodies  nor  the  renovation  of  public  buildings.  Finland  included  the  amount  of  cumulative 
energy  savings  of  16.12  Mtoe  to  be  achieved  over  the  period  from  1  January  2021  to  31 
December 2030 and an explanation on how the annual savings rate and the calculation baseline 
were established. 

Finland has addressed recommendation 12. Finland set out complete policies and measures 
to achieve the national contributions on energy efficiency and to achieve the required amount 
of cumulative end-use energy savings. In the plan, Finland specified how the energy efficiency 
first  principle  will  be  implemented.  Finland  specified  some 263 energy  efficiency  financing 
programmes and support schemes. 

Finland has partially addressed  recommendation 13. Finland did not include an updated 
ambition level264 to ensure a highly energy efficient and decarbonised national building stock 
by  2050.  The  final  plan  contains  intermediate  milestones  for  2030  and  2040  for  the 
renovation  of  residential  and  non-residential  buildings.  Finland  included  energy  savings 
milestones for the buildings stock but did not detail the impact in terms of energy savings 
of  each  new  measure  related  to  buildings,  nor  provide  sufficient  information  in  terms  of 
funding, costs, energy and emissions savings. The plan contains information on policies and 
measures addressing deep renovation with a specific focus on vulnerable consumers, as well 
as decarbonisation of heating or installation of renewables in buildings. 

259 Strictly, the Final NECP states that Finland’s national energy and climate strategy will be completed in spring 
2025.  
260  Finland  provided  values  for  a  WEM  scenario  instead,  which  would  contribute  22.8  Mtoe  final  energy 
consumption. With existing measures there is still a gap of 10.68% compared to the target calculated with respect 
to the indicative results of the 2020 reference scenario, a gap of 11.71% compared to the indicative results of the 
2020 updated reference scenario and a gap of 10.68% compared to the corrected indicative contribution. 
261 Finland  provided  values  for  a  WEM  scenario  instead,  which  would  contribute  30.7  Mtoe  primary  energy 
consumption. With existing measures there is still a gap of 3.1% compared to the indicative results of the Article 
4 and Annex I (REF2020 scenario), and a gap of 3.3% compared to the indicative results of the Article 4 and 
Annex I (updated REF2020 scenario). 
262 However, it reported the total obligation by 2030, equal to 28375 ktoe (330.8 GWh) 
263 The report is focused on information and communication about financing. 
264 The Finnish NECP explicitly points out that “no need for a quick update was detected” with respect to the 
targets from the 2020 Long-Term Renovation Strategy. 

227 

 
 
 
 
 
 
 
2.4  ENERGY SECURITY DIMENSION 

Finland has partially addressed recommendation 14. On gas, the plan provides estimations 
for the evolution of natural gas consumption, which is expected to decrease from 76 PJ in 2020 
to 27 PJ in 2030 and 16 PJ in 2040.  

For electricity, the plan provides details on the various options to secure long-term supply of 
alternative  nuclear  materials,  including  nuclear  fuel,  to  the  Loviisa  nuclear  power  plant 
(Russian  VVER  design)  and  clarifies  the  operator’s  commitment  to  ensure  diversified  fuel 
supply. The plan does not contain information on the measures for long-term management of 
nuclear  waste.  However,  the  information  is  covered  in  the  4th  national  report  on  waste 
management submitted in August 2024. The plan does not set an objective target for energy 
storage, but  the Government’s  strategy is  to  increase the deployment  of  energy storage and 
some partial investment subsidies are available. 

In  the  oil  sector,  the  plan  contains  forecasts  on  oil  consumption  until  2050  and  describes 
possible measures to ensure the adequacy of the oil infrastructure in the long run (refineries, 
oil stocks).  

2.5  INTERNAL ENERGY MARKET DIMENSION 

Finland  has  partly  addressed  recommendation  15.  Finland  does  not  elaborate  on  the 
quantification of flexibility needs but it includes policies and measures that enhance flexibility. 
The plan provides estimates for the demand side response capacity in different energy markets 
and notes that it is expected to increase.  

Regarding  storage,  Finland  informs  that  there  are  several  planned  storage  projects  under 
development (for instance, batteries and pumped hydro), the estimated combined capacity of 
which  is  approximately  5  GW.  Finland  explains  that  while  there  are  currently  no  specific 
targets for energy storage capacity, the Government’s strategy is to increase its deployment, 
including through the National Battery Strategy 2025. 

Finland  has  partly  addressed  recommendation  16.  The  assessment  of  the  households 
affected by energy poverty is limited, with the only indicator being the number of non-payment 
records  regarding  electricity  bills.  Finland  did  not  provide  a  specific  measurable  reduction 
target  but  provided  additional  details  on  existing  measures  to  address  poverty  and  energy 
efficiency.  While  there  is  information  on  some  financial  resources  of  the  structural  energy 
measures,  there  is  no  overview  of  all  relevant  financial  resources  nor  of  potential  further 
measures to address energy poverty. 

2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Finland  has  partially  addressed  recommendation  17.  The  final  plan  includes  high  level 
targets  and  objectives  in  research,  innovation  and  competitiveness  to  deploy  clean 
technologies, establishing a pathway for 2030 to support the decarbonisation of industry and 
promote the transition of businesses towards a net zero and circular economy. 

Policies  and  measures  include  an  initiative  called  Growth  Engines,  a  cooperation  network 
supporting new business activities. The objectives on R&I expenditure are set at 4% by 2030 

228 

 
 
 
 
 
 
(both public and private, for all sectors). However budgetary information is limited to budgets 
from 2018-2019.  

The plan does not put forward concrete policies and measures to promote the development of 
net-zero projects,  including  those relevant  for the energy intensive industries. However,  the 
Finnish Government is preparing an eight-year plan on R&D funding and other aspects related 
to RDI policy.  

The plan does not describe a predictable and simplified regulatory framework for permitting 
procedures  for manufacturing,  nor  how access  to national  funding will be simplified where 
relevant.  The  plan  partly  provides  information  on  some  policies  and  measures  for  the 
digitalisation of the energy system, focussing on the rollout of smart meters. The plan does not 
provide measures on the development of clean-energy-related skills, and to facilitate open trade 
for resilient and sustainable supply chains of key net-zero components and equipment. 

Finland does not provide clear competitiveness targets and measures for regional cooperation 
in R&I, nor information on measures and investments to bridge potential skills gaps for the 
energy transition. The role of circular economy for decarbonisation is generally well integrated.  

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Finland  has  not  addressed  recommendation  18.  The  plan  provides  estimates  of  the  total 
investments in the clean energy transition planned by individual businesses (EUR 257 billion), 
covering various sectors. It also includes dedicated information on the decarbonisation of the 
transport  sector.  However,  it  does  not  provide  an  estimate  of  total  investment  needs,  nor  a 
breakdown by funding source (public/private). A description of the types of instruments used 
or envisaged is only included for specific measures. The assessment is only based on a bottom-
up analysis. The information provided in the plan is not sufficient to estimate whether there is 
a potential financing gap with respect to the investment needs, or how this would be filled. 

Finland  has  partially  addressed  the  need  to  provide  a  robust  assessment  of  the 
macroeconomic  impact  of  the  planned  policies  and  measures.  The  macro-economic 
assessment  included  in  the  plan  focuses  only  on  expected  labour  market  developments  and 
challenges while discussing these in qualitative terms. 

2.8  JUST TRANSITION 

Finland  has  partially  addressed  recommendation  22.  The  plan  provides  some  general 
information  on the impact  of the transition  to  climate neutrality  on skills, based on  a study 
funded  by  the  Finnish  Government.  However,  it  does  not  include  an  analysis  of  the  social, 
employment  and  skills  impacts  of  the  transition  on  the  planned  objectives,  policies,  and 
measures to support a just transition. Moreover, the plan does not specify the form of support, 
the impact of initiatives or the resources available, except for the Just Transition Fund (JTF) 
and a small amount from ETS revenues. The analysis focuses on the JTF and the Territorial 
Just  Transition  Plans  (TJTPs).  In  terms  of  alignment  with  TJTPs,  the  plan  mentions  the 
commitment to reduce peat use by 50% by 2030 as a TJTPs commitment.  

The plan lacks the analytical basis needed for the preparation of the Social Climate Plan, such 
as information on the estimated impact of ETS2 and the identification of vulnerable groups, 
albeit including some initial reflections on the latter. Finland also provides limited information 

229 

 
 
 
 
 
on how it intends to organise the preparation of its Social Climate Plan. However, the plan only 
partly  explains  how  the  policy  framework  identified  in  the  NECP  will  contribute  to  the 
preparation of Finland’s Social Climate Plan and how the consistency of the two plans will be 
ensured.  

2.9  PUBLIC CONSULTATION 

Finland  has  partially  addressed  recommendation  23.  Finland  organised  two  rounds  of 
public consultation in the preparation of the NECP. The first consultation was organised from 
14  April  to  18  May  2022  as  part  of  the  preparations  of  the  National  Climate  and  Energy 
Strategy, the Medium-term Climate Change Policy Plan and the Climate plan for the Land Use 
Sector of Finland, containing the targets and policy measures set in the draft updated NECP 
delivered in 2023. The consultation for the final plan was organised from 22 May to 10 June 
2024, close to the submission date (30 June). Finland received 107 comments for the strategy 
and  57  comments  for  the  final  plan.  The  plan  provides  a  summary  on  the  content  of  the 
comments of both consultations and how the comments were considered in the NECP.  

2.10 REGIONAL COOPERATION 

Finland did not receive Commission recommendations on regional cooperation.  

2.11 ANALYTICAL BASIS 

Finland has not addressed recommendation 21. The final plan includes updated projections 
compared with the draft plan but does not provide WAM projections on how the energy system 
will develop. The plan mentions that a WAM scenario is being developed and will be published 
in 2025.  

The plan references a description of the analytical framework, with projections reaching 2040. 
It  embeds  economic,  social,  employment  and  skills  impacts. The  methodologies  used  are 
described in detail in referenced documents.   

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

Finland  has  partially  addressed  recommendation  19.  The  final  updated  NECP  covers 
sufficiently the main reforms and investments of the Recovery and Resilience Plan (RRP) that 
contribute to the implementing the objectives, targets and contributions of the Energy Union.   

3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

The Commission encourages Finland to ensure a timely and complete implementation of the 
measures needed to achieve its national climate and energy targets. Finland is invited to pay 
particular attention to the following main elements:  

•  On ESR, finalise the design of additional measures to reduce emissions in the effort sharing 
sectors, in line with the government’s preparation of a new energy and climate strategy and 

230 

 
 
 
 
 
the  third  medium-term  climate  change  policy  plan. Analyse  the  projected  impact  of  the 
additional measures on GHG emissions.  

•  On LULUCF, implement additional policies to reduce emissions from organic soils and 
increase  forest  sink.  Policies  should  focus  on  sustainable  forest  management  practices, 
promoting afforestation and reforestation. Implement measures to reduce emissions from 
drained organic soils.  Establish a robust monitoring system  to  track the effectiveness  of 
these policies. Develop geographically explicit datasets and higher tier levels to ensure the 
accuracy of net removal estimates. 

•  On adaptation, use relevant ongoing local, national and sectoral processes to detail their 

contribution to the different Energy Union dimensions.   

•  Clarify the list of existing fossil fuel subsidies and set a roadmap and specific measures for 

their gradual phase-out.  

•  On industry, support investments in innovative technologies, including CCUS. Ensure that 
raw  materials  are  sourced  sustainably,  strengthening  recycling  and  energy  efficiency, 
especially for the pulp and paper industry. 

•  On energy efficiency, put in place measures to achieve the higher ambition by 2030 for 
primary energy consumption. Diversify energy efficiency measures for transport beyond 
fiscal measures. Set up a strategy to support and monitor the proper implementation of the 
efficiency first principle. 

•  On  buildings,  ensure  that  the  ambition  level  in  the  building  sector  is  in  line  with  2050 
decarbonisation  efforts  and  clarify  policies  and  financing  of  energy  efficiency  measures 
with clearly identified budgets and expected outcomes in terms of energy and emissions 
savings. 

•  Continue efforts to diversify nuclear fuel supplies for its VVER reactors and ensure the 

• 

long-term supply of spare parts and maintenance services.  
Improve data quality for vulnerable households and energy poverty, both quantitative and 
qualitative, to identify fit for purpose measures to reduce energy poverty.   

•  Develop a comprehensive just transition strategy that analyses the social and employment 

impacts of the transition and allocates appropriate resources.   

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Sweden 

1  Overview of key objectives, targets and contributions in the final NECP 

Final updated NECP submitted on 28.06.2024 

Table 1: Summary of key objectives, targets and contributions of  Sweden’s final updated NECP 

2020 

Progress based 
on latest 
available data 

2030 national 
targets and 
contributions 

Assessment of 
2030 ambition 
level 

2022: -36.9% 
2023: -37.8%265  

-50% 

-3.96 Mt CO2 
eq. (additional 
removal 
target) 

2022: Reported 
net removals of 
– 41Mt CO2 eq  

2023: 66.4%  

67% 

Binding target for 
greenhouse gas (GHG) 
emissions compared to 
2005 under the Effort 
Sharing Regulation (ESR) 
(%)  

Binding target for 
additional net GHG 
removals under the 
Regulation on Land Use, 
Land Use Change and 
Forestry (LULUCF) 

National 
target/contribution for 
renewable energy: 

Share of energy from 
renewable sources in gross 
final consumption of 
energy (%) 

60.1% 
(SHARES) 
49% 
(target) 

National contribution for 
energy efficiency: 

Primary energy 
consumption  

43.4 Mtoe 

2023:  41.41 
Mtoe 

41.19 Mtoe 

NECP: -43.8%  
However, SE is 
expected to meet 
the 2030 target 
with ESR 
flexibilities 

Insufficient 
ambition: 
projected gap of 
13.32 Mt CO2 eq 
in 2030  

SE contribution of 
67% is 
signifcantly 
below the 76% 
required 
according to the 
formula set out in 
Annex II of the 
Governance 
Regulation266. 

SE primary 
energy 
consumption 
contribution is 
41.19 Mtoe. EED 
recast Annex I 
formula results: 
35.42 Mtoe 
(Reference 
Scenario) or 35.84 
Mtoe (Updated 

265  The ESR emissions in 2022 are based on 2024 final GHG inventory reports, and 2023 emissions are based on 
2024 approximated inventory reports. The percentage reduction is compared with the 2005 emissions as set out 
in Annex I of Commission Implementing Decision (EU) 2020/2126. However, the final ESR emissions for 2021-
2025 will only be established in 2027 after a comprehensive review. 
266 Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action OJ L 328, 21.12.2018, 
p. 1–77 (‘Governance Regulation’). 

232 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Final energy consumption 

30.3 Mtoe 

2023: 30.26 
Mtoe 

30.09 Mtoe 

Level of electricity 
interconnectivity (%)267 

24.2% 

2024: 12.8% 

15% 

Source: Eurostat; Sweden’s final updated national energy and climate plan 

Reference 
Scenario). 

SE final energy 
consumption 
contribution of 
30.09 Mtoe is not 
in line with the 
national  
contribution of 
25.41 Mtoe 
submitted by the 
Commission. 

SE is below the 
EU-wide 
interconnectivity 
target. 

2  CONSIDERATION  OF  COMMISSION  RECOMMENDATIONS  ON 

DRAFT NECP UPDATE 

In  December  2023,  the  Commission  published  a  thorough  assessment  of  Sweden’s  draft 
updated  NECP  and  provided  recommendations 268 for  the  preparation  of  the  final  updated 
NECP. Sweden submitted its final updated NECP on 28 June 2024, in line with the deadline 
of 30 June 2024.269 

2.1  DECARBONISATION 

Based on the projections available in the plan, which are only provided for the “with existing 
measures”  (WEM)  scenario,  Sweden  expects  to  decrease  total  GHG  emissions  (excluding 
LULUCF and international aviation) by between 47% by 2030 compared to 1990. Sweden has 
a national target of climate neutrality by 2045 with goal to reduce GHG emissions (excluding 
LULUCF) by 85% compared 1990. Sweden projects to reach reductions of 70% compared to 
1990 by 2045, falling short of this goal.   

2.1.1  Effort Sharing Regulation 
Sweden  has  addressed  recommendation  number  1.  The  final  NECP  provides  sufficient 
details  on  how  Sweden  will  meet  its  ESR  target  of  a  50%  reduction  in  emissions  by  2030 
compared to 2005. The plan provides projections only with existing measures (WEM) for a 
baseline scenario and sensitivity case270. Sweden projects to achieve a 43.8% reduction in ESR 

267  Calculated by the European Commission based on the ETNSO-E data (Winter Outlook 2024). The 2020 figure 
also covers interconnectors with the neighbouring countries outside the EU. The 2030 level represents the general 
interconnectivity target of 15%.  
268 SWD(2023) 923 final, and Commission Recommendation of 18 December 2023, C/2023/9613. 
269 Article 14(2) of Governance Regulation. 
270 The  final  NECP  outlines  that  the  sensitivity  case  scenario  adjusts  the  projections  of  the  amount  of  energy 
consumed by the transport sector, as recent statistics have shown a different trend compared to what was initially 
adopted in the baseline scenario. The sensitivity case is considered the more likely scenario.  

233 

 
 
 
 
 
 
 
 
 
 
emissions by 2030 compared to 2005 levels, a gap of 6.2 percentage points to the national ESR 
target. However, with the use flexibilities available under the ESR (banking as well as the use 
of ETS allowances), Sweden is expected to exceed its 2030 target.  

The  final  plan  complemented  the  information  on  the  policies  and  measures  provided  in  the 
draft but a clearer description of scope, timeline and expected impact on GHG emissions would 
be useful, particularly in the case of the buildings sector. In 2022, GHG emissions from ESR 
sectors  represented  60.3%  of  the  total  in  Sweden  (expected  to  be  63.8%  in  2030)271,  with 
transport sector projected to represent the largest share. ESR emissions for the transport sector 
decreased  by  an  average  of  4.1%  annually  between  2015  and  2022  (biofuel  blending 
contributed to the reductions), while Sweden projects they will decrease by a smaller amount 
(1.3%) annually between 2022 and 2030, leading to an overall emissions reduction of 41.5% 
for the sector between 2005 and 2030. The electrification of the transport sector is expected to 
play a large role in this emissions reduction, and the Government is promoting measures such 
as the roll-out of home charging in multi-apartment buildings to accelerate this transition. In 
the  case  of  agriculture,  the  plan  includes  some  measures  but  not  the  quantified  impact  on 
emission  reductions.  A  good  example  is  the  inclusion  of  a  rewetting  scheme  that  includes 
overview of the planned funding and achieved emissions reductions. 

With  regards  to  non-CO2  emissions,  notably  methane  and  N2O,  the  plan  contains  some 
policies and measures but fails to integrate increased ambition, notably for methane. Methane 
from enteric fermentation of cattle and N2O from agricultural soils are the biggest sources of 
non-CO2 emissions, accounting for almost a fifth of Sweden’s ESR emissions. There is not 
sufficient information on measures designed to reduce methane from enteric fermentation of 
cattle, except for some advice on livestock management. 

The  plan  refers  to  the  introduction  of  the  emissions  trading  system  for  fuel  combustion  in 
buildings,  road  transport  and  additional  sectors  (ETS2).  The  WEM  scenario  projections 
account for the effect of ETS2, but do not clearly consider the impact of ETS2 in achieving the 
ESR target. 

2.1.2  LULUCF 
Sweden has partially addressed recommendation 3. The LULUCF sector absorbed roughly 
91%  of  the  total  GHG  emissions  in  2022  (–41MtCO2  eq.).  According  to  the  LULUCF 
Regulation, Sweden has to enhance its net removals by -3.96 Mt CO2eq in 2030 as compared 
to its yearly average in the 2016-2018 reference period. According to the latest reported figures 
in 2022, Sweden has decreased its performance by approximately 3.8 Mt CO2eq in comparison 
to its yearly average in the 2016-2018 period. Moreover, taking into account its projections for 
2030, under the average growth scenario for forest land, Sweden will still have a gap of 13.32 
Mt CO2 eq in 2030. Under the scenario of reduced forest growth, total net removals would be 
around 29 Mt CO2 eq t, bringing the gap to the target in 2030 to around 19 Mt CO2 eq. 

The final plan includes updated projections, based on forest growth, indicating that Sweden 
will  likely  fall  short  of  the  2030  target.  This  highlights  the  need  to  identify  and  implement 

271 Excluding LULUCF.  

234 

 
 
 
 
 
 
additional measures in the sector. The plan indicates that a process is underway to identify a 
strategy to contribute to delivering on the LULUCF targets. 

The plan provides additional information on how public funding and private financing through 
carbon farming schemes are used to reach the LULUCF target. The final plan does not include 
additional information on the progress in ensuring higher tier levels and geographically explicit 
datasets  needed  to  ensure  the  robustness  of  net  removal  estimates,  but  the  Environmental 
Protection Agency delivered a set of recommendations on this topic in September 2024. 

2.1.3  Carbon Capture and Storage 
Sweden has addressed recommendation number 2. The plan contains an assessment of the 
expected volumes of CO2 to be captured in the upcoming decades. By 2030, Sweden aims to 
capture more than 1.5 million tonnes per year (Mtpa) of CO2 from industrial installations and 
1.2-2.2  Mtpa  of  CO2  from  biogenic  sources.  With  regards  to  the  potential  for  CO2  storage, 
Sweden is not expected to have a CO2 injection capacity by 2030. The volumes captured by 
2030 are planned to be transported by ship to Norway for storage. Sweden’s plans with regards 
to CCUS are robust, with competitive financial incentives provided, especially for bioenergy 
with carbon capture and storage (BECCS).  

2.1.4  Adaptation 
Sweden has partially addressed recommendation 4.  The plan refers to the country’s new 
national adaptation strategy and to the National Climate Adaptation Action Plan to respond to 
the  recommendation,  acknowledging  the  importance  of  integrating  adaptation  planning.  It 
partially embeds adaptation policies and measures in the relevant Energy Union dimension.  

The plan contains a partial analysis of climate vulnerabilities and risks. It identifies several 
significant risks related to forest fires, as well as increased occurrence of pests, diseases, and 
invasive species. It also refers to the 2021 climate and vulnerability assessment conducted by 
the Swedish National Grid, which provides insights into the potential impacts of climate change 
on the electricity system.  However, it is short of quantifiable assessment of impacts.   Sweden’s 
municipalities  are  required  to  carry  out  risk  and  vulnerability  assessments  to  deal  with 
extraordinary events and crises.    

The plan partially outlines the links to the specific Energy Union objectives and policies, that 
adaptation  policies  and  measures  are  meant  to  support,  particularly  for  the  energy  security 
dimension. It references the recently adopted National Strategy and Action Plan on Adaptation 
to  Climate  Change,  which  provides  the  basis  for  the  government's  work  on  adaptation  to 
climate  change  over  the  next  five  years.    The  government  has  also  appointed  a  special 
investigator  to  analyse  and,  if  necessary,  propose  new  or  adapted  legislation  on  climate 
adaptation measures. However, the impacts and benefits of adaptation policies on other Energy 
Union objectives have generally not been quantified. 

The  plan  sets  out  some  additional  adaptation  policies  and  measures  to  support  the 
achievement of national objectives, targets and contributions under the Energy Union, notably 
under the National Strategy and Action Plan on Adaptation to Climate Change.  However, the 
updated NECP does not include an in-depth overview of specific targets and measures. The 
plan  provides  insufficient  details  on  the  extent  to  which  investments  aimed  at  minimising 
environmental impacts and biodiversity loss contribute to climate adaptation. 

235 

 
 
 
 
 
2.1.5  Fossil Fuels 
Sweden has partially addressed recommendation 19. The plan indicates the need to phase 
out fossil fuel subsidies in line with international commitments and mentions the aim to reduce 
its support for fossil fuels by more than one third from 2019 to 2025. However, it does not 
provide a clear explanation of how it intends to phase out fossil fuel subsidies, including the 
specific measures that will be taken and the timeline for the phase-out. 

2.2  RENEWABLES  

Sweden has partially addressed Commission recommendation 5. The plan puts forward an 
updated national contribution for renewable energy of 67% of gross final energy consumption 
in 20303. Even though this contribution is slightly higher than 65% included in the draft NECP, 
it remains significantly below the level (of 76%) calculated in line with formula of Annex II of 
the Governance Regulation. The updated indicative trajectory to reach the 67% contribution in 
2030 is provided, including specific reference points for 2025 (57%) and 2027 (61%)4, which 
are below the trajectory calculated in line with the increased EU 2030 renewable energy target 
of 42.5% (61% and 66% respectively). 

Sweden has partially addressed recommendation 6. Sweden has included projections on the 
overall renewable energy share and per sector for 2035 and 2040 (with the renewable share to 
reach 76% in 2040). The final NECP includes updated projections for the renewable energy 
share for specific sectors: 81% in electricity, 46% in transport, 79% in heating and cooling in 
2030, with the renewable energy share in district heating and cooling projected to reach 80% 
in 2030 (by specifying that those shares do not include waste heat). Sweden has also included 
in its final updated plan the projected shares of renewable energy in industry of 74% and 89% 
in  buildings in  2030, respectively,  but  it does not  confirm  whether those  constitute specific 
targets to achieve the indicative sub-targets for buildings and industry in line with Directive 
(EU) 2018/2001 (the ‘revised RED II’)272. As regards renewable fuels of non-biological origin 
in industry, Sweden indicates that the binding minimum level of 42% will be achieved by 2030 
as projections show that hydrogen in Sweden will be produced from renewable electricity by 
2040.  The  updated  plan  does  not  contain  information  on  the  innovative  renewable  energy 
technologies to achieve the indicative target 5% set in the revised RED II.  

Sweden  has  partially  addressed  recommendation  7.  Sweden  included  in  its  final  NECP 
some additional information on policies and measures merely updating the existing measures 
included in the draft plan. As regards the designation of renewables acceleration areas the final 
Plan indicates that the Swedish Energy Agency shall give a particular priority to identifying 
larger  interlinked  areas  in  line  with  Article  15(c)  of  the  revised  RED  II,  which  should  be 
finalised by the Government on 25 October 2025, without specifying which technologies other 
than wind the mandate would cover.   

As  regards  district  heating  and  cooling,  Sweden  states  that  Swedish  Energy  Agency  has 
adopted a district and combined heat and power strategy which shows that cogeneration and 
district heating will play an important role in the future, considering the impacts of an increased 

272 Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU) 
2023/2413  

236 

 
 
 
 
 
 
electricity production from solar and wind power. Furthermore, the Swedish government has 
tasked  the  Swedish  Energy  Agency  to  examine  the  conditions  for  setting  up  and  operating 
renewable energy communities and citizen energy communities, and whether further efforts 
are needed to promote such communities.  

Sweden has partially addressed recommendation 8. The plan provides an assessment of the 
domestic supply of forest biomass for energy purposes and mentions that the projected use of 
forest  biomass  for  energy  production  is  compatible  with  Sweden’s  obligations  under  the 
revised  LULUCF  Regulation.  Sweden  includes  measures  to  promote  the  sustainable 
production of biogas/biomethane but does not report a target for 2030.  

Sweden  has  partially  addressed  recommendation  9  as  the  plan  lacks  details  on  the 
procedural steps and timelines for most policies and measures.  

2.3  ENERGY EFFICIENCY DIMENSION 

Sweden  has  not  addressed  recommendation  10.  The  plan  includes  an  indicative  national 
contribution of 30.1 Mtoe to the Union’s binding final energy consumption target for 2030. 
This contribution is not in line with Article 4 of Directive (EU) 2023/1791 (‘EED recast’)273, 
nor equal to the corrected indicative national contribution that the Commission submitted to 
Sweden in March 2024. There is still a gap of 19.9% compared to the target calculated with 
respect to the indicative results of the 2020 reference scenario and a gap of 21.9% compared to 
the  target  calculated  with  respect  to  the  indicative  results  updated  2020  reference 
scenario. Sweden  included  an  indicative  national  contribution  of  41.2  Mtoe  to  the  Union’s 
indicative primary energy consumption target for 2030. This contribution is not in line with 
Article 4. There is still a gap of 16.3% compared to the target calculated with respect to the 
indicative results of the 2020 reference scenario, and a gap of 14.9% compared to the target 
calculated with respect to the indicative results updated 2020 reference scenario.  

Sweden did not include the yearly amount of energy consumption reduction to be achieved by 
all public bodies. The plan does not report the total floor area of heated and cooled buildings 
owned by public bodies to be renovated yearly, nor the corresponding yearly energy savings to 
be achieved nor specify if Sweden opts for the alternative or default approach. The plan does 
not  set  out  complete  policies  and  measures  neither  to  achieve  the  reduction  of  energy 
consumption from public bodies nor the renovation of public buildings.2    

Sweden has partially addressed recommendation 11. The plan sets out complete policies 
and measures on energy efficiency but does not quantify the expected energy savings and the 
contribution for the reported measures. The main measures include inter alia energy and CO2 
taxes above the levels of Energy Taxation Directive, aid for energy efficiency in single-family 
houses4 and tax deductions for building renovations5. Moreover, Sweden did not specify how 
the energy efficiency first principle will be implemented or monitor its implementation.  

Sweden includes the amount of cumulative energy savings of 20.4 Mtoe to be achieved over 
the  period  from  2021  to  2030  and  an  explanation  on  how  the  annual  savings  rate  and  the 
calculation  baseline  are  established.  Sweden  sets  out  complete  policies  and  measures7  to 

273 Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast). 

237 

 
 
 
 
 
 
achieve the required amount of cumulative end-use energy savings by 2030 and quantifies the 
savings from the reported measures to ensure the achievement of the cumulative target. Sweden 
does not include the quantification of the savings from measures targeting energy poverty.   

Sweden sets out adequate measures to promote energy audits and energy management systems 
and specified some energy efficiency financing programmes and support schemes, including 
financial instruments and public guarantees to mobilise private investments and additional co-
financing. Sweden did not specify existing policy measures to promote the uptake of energy 
efficiency lending products and innovative financing schemes.  

 Sweden  partially  addressed  recommendation  12.  Sweden  does  not  include  an  updated 
ambition level to ensure a highly energy efficient and decarbonised national building stock and 
to transform existing buildings into zero-emission buildings by 2050. Sweden does not update 
the milestones for 2030 and for 2040 from the long-term renovation strategy (LTRS 2020). 
The plan recalls the milestones of specific energy consumption, distribution of energy classes 
in the building stock and share of fossil fuels used in buildings up to 2050 comparing them 
with  the  previous  milestones,  without  providing  numerical  values.  The  milestones  for  the 
renovation  of  buildings  include  both  non-residential  and  residential  buildings.  Sweden  has 
included energy savings milestones for the building stock but has not detailed the impact of the 
measures put forward.  

Energy and CO2 taxes in buildings are expected to generate significant savings under Article 8 
of EED Recast, however the NECP does not describe sufficiently the link between measures 
and financing on one hand and renovation rates and energy savings on the other hand.  

2.4  ENERGY SECURITY DIMENSION 

Sweden has partially addressed recommendation 13.  The final plan does not define clear 
objectives in terms of diversification of energy sources, nor does it explain how Sweden intends 
to further encourage gas demand reduction towards 2030. According to projections, it appears 
that the consumption of natural and urban gas is expected to increase towards 2040, but no 
precise figure is provided.  

Sweden appears to clarify that there are no specific national objectives for the deployment of 
energy storage.  

The  plan  contains  projections  on  oil  consumption  until  2040.  However,  the  plan  does  not 
describe  the  measures  taken  to  assess  the  adequacy  of  the  oil  infrastructure  in  the  long  run 
(refineries, pipeline, oil stocks) with the expected oil demand decline and the move to lower-
carbon alternatives.   

While the plan refers to the Strategy and Action Plan on Adaptation to Climate Change, it does 
not provide specific details on how this will contribute to enhancing the climate resilience of 
Sweden's energy system. 

The final NECP describes measures taken by both operators of nuclear power plants in Sweden 
to avoid dependence on Russian uranium and nuclear fuel. However, the plan does not provide 
information on the long-term supply of spare parts and maintenance services for the existing 
reactors in the country. It provides information on the steps by the Swedish Government to 

238 

 
 
 
 
 
analyse the need to adapt the existing nuclear waste management programme and to ensure its 
financing.  

2.5  INTERNAL ENERGY MARKET DIMENSION 

Sweden  has  partially  addressed  recommendation  14. The  plan  provides  measures  to 
develop  competitive  wholesale  markets  and  to  phase  out  measures  interfering  with  market 
signals.  In  particular,  the  plan  outlines  the  ongoing  work  to  improve  the  functioning  of  the 
wholesale  market  before  the  introduction  of  a  capacity  mechanism.  Concerning  market 
integration, the plan has defined a programme of work with a vision to 2030 together with other 
Nordic countries focused on several objectives to enhance regional integration and optimise 
electricity  markets  and  flows  in  the  region.  Indeed,  a  major  project  to  better  integrate 
renewables and optimise electricity trading in the Nordic region, known as flow-based market 
coupling, went live in October 2024.   

The  plan  does  not  elaborate  on  the  quantification  of  flexibility  needs  but  it  does  set  clear 
objectives  for  non-discrimination  of  demand  response,  storage,  and  flexibility  and  includes 
policies and measures that enhance flexibility and enable a non-discriminatory participation of 
new  flexibility  services.  In  particular,  the  plan  outlines  the  objective  of  further  developing 
energy  markets  at  regional  level  for  balancing  products,  which  would  allow  more  types  of 
resources  and  actors  to  participate  in  trade.  Furthermore,  legislation  enables  electricity  grid 
companies to  test  on smaller scale tariffs that can stimulate more efficient  grid use through 
demand  response  and  a  Dialogue  Forum  aims  to  identify  how  regulatory  frameworks  and 
methodologies need to be developed to create a well-functioning market where aggregators can 
offer their flexibility and support services.   

Even though the plan provides a good overview of measures promoting flexibility solutions in 
the context of facilitating energy system integration, it does not provide information on specific 
measures for implementing Article 20a of the revised RED II. 

New requirements on the measurement, calculation and reporting of transferred electricity will 
apply from 2025 and promote more reliable and efficient network operation and contribute to 
consumer empowerment by enabling the integration of microgeneration of RES.    

Sweden has partially addressed recommendation 15. There is ongoing work towards further 
addressing energy poverty by defining energy poverty according to the EU legal framework, 
notably  Article  8,  10  and  24  of  the  recast  EED,  taking  into  account  the  Commission 
Recommendation EU (2023/2407) and in accordance with the legal transposition period. This 
work should help determine the number of energy poor at national level and be completed with 
the  identification  of  a  reduction  target  and  structural  measures  on  how  to  reduce  energy 
poverty.  The  plan  provides  information  on  the  campaigns  carried  out  in  2021  and  2022  to 
mitigate the impact of high energy prices, based on which further structural measures can be 
taken.   

Action is also taken to strengthen energy consumer protection through the memorandum of 
January 2024, aimed at protecting contractual rights including the contract termination rules.   

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2.6  RESEARCH, INNOVATION AND COMPETITIVENESS 

Sweden  has  partially  addressed  recommendation  16.  The  plan  does  not  include  national 
objectives  in  research,  innovation,  and  competitiveness  to  deploy  clean  technologies, 
establishing  a  pathway  for  2030  and  2050  with  a  view  to  support  the  decarbonisation  of 
industry and promote the transition  of businesses towards  a net  zero and circular  economy. 
Nonetheless, the plan puts forward policies and measures to promote the development of net-
zero  projects,  including  those  relevant  for  the  energy  intensive  industries.  For  instance,  to 
promote  industrial  decarbonisation.  the  plan  presents  the  Industry  Leap,  which  can  support 
projects running until up to 2031 and covers strategically important net zero technologies and 
activities (such as biofuels, hydrogen production, battery production, CCS). However, the plan 
only partly details specific policies and measures to promote and implement research in the 
identified priority technological areas. The plan mentions the Net Zero Industry Programme, 
which aims to accelerate the development of the Swedish manufacturing industry towards net-
zero  emissions.  While  business  development  and  commercialisation  programmes  are 
mentioned  to  support  companies,  the  plan  does  not  describe  a  predictable  and  simplified 
regulatory framework for permitting procedures for manufacturing or how access to national 
funding will be simplified where needed.  

The plan does not elaborate on the opportunities provided by the digitalisation of the energy 
system but described measures taken to bridge potential skills gaps for the energy transition, 
for instance through the Budget Bill for 2024.  

The  strategy  for  Sweden’s  external  trade,  investment  and  global  competitiveness  identifies 
energy  technology  and  energy  transition  as  areas  that  offer  major  export  opportunities. 
However, the plan does not provide detailed policies and measures to facilitate open trade for 
resilient and sustainable supply chains of key net-zero components and equipment. 

2.7  FINANCING THE ENERGY AND CLIMATE TRANSITION 

Sweden  did  not  address  recommendation  17.  The  plan  provides  estimates  of  investment 
needs only in some sectors including those related to the transmission network for the years 
2022-2031, which amount to SEK 170 billion. Moreover, the methodology underlying the few 
estimates is not clearly presented. The investment estimates pertain to the WEM scenario only. 

The  plan  does  not  provide  an  estimate  of  investment  needs  for  specific  policy  measures  to 
2030,  and  no  breakdown  is  presented  for  public  and  private  investments.  No  investment 
estimates are provided for the industry, transport, or buildings sectors.  

Information on funding sources is limited and scattered throughout the plan. Except for nuclear 
energy, the plan does not describe in detail how the reforms and measures will mobilise private 
investments. The information provided in the plan is not sufficient to estimate whether there is 
a potential financing gap with respect to investment needs, or how it would be filled.  

2.8  JUST TRANSITION 

Sweden has partially addressed recommendation 21. The plan describes the impact of the 
energy  and  climate  transition  on  education  and  skills,  mentioning  the  challenge  of  skills 

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shortages as an obstacle to electrification. It also refers to the Swedish Energy Agency’s report 
on the effects on health and the environment of electrification and an analysis of the Public 
Health Agency of the impact of climate change on public health, developing an action plan to 
adapt its activities to climate change. However, the plan does not include the analysis of the 
social  and  employment  impacts  of  transition  to  climate  neutrality  nor  the  impacts  on  most 
vulnerable groups. 

Moreover,  the  plan  does  not  specify  the  form  of  support,  the  impact  of  initiatives  or  the 
resources available, except for a general reference to the Just Transition Fund 

The plan does not provide the proper analytical basis needed for the preparation of the Social 
Climate Plan. While it includes information on the estimated impact of ETS2, the plan does 
not identify vulnerable groups -if any- and does not refer to any definition of energy transport 
poverty.  The  plan  does  not  explain  how  the  policy  framework  identified  in  the  NECP  will 
contribute to the preparation of Sweden’s Social Climate Plan nor how the consistency of the 
two plans will be ensured.  

2.9  PUBLIC CONSULTATION 

Sweden  has  partially  addressed  recommendation  22.  Sweden  organised  a  public 
consultation in the autumn of 2023, where members of the public were invited to comment on 
the draft updated NECP via the Swedish Energy Agency’s website. It is unclear if sufficient 
time  was  given  to  allow  members  of  the  public  to  comment  on  the  draft  plan,  however  a 
summary of the submission input is provided.   

Sweden also held a hearing in May 2024 where key stakeholders were given the opportunity 
to comment on a draft of the final updated NECP. This round of consultations started relatively 
close to the submission of the final plan. The draft was made available on the Energy Agency’s 
website in April, and a timeframe of three weeks was given to allow stakeholders to comment. 
The final plan includes a summary of the hearing and the written inputs. It does not provide 
however how the views expressed during the consultations had been integrated into the final 
plan.  

2.10 REGIONAL COOPERATION 

Sweden  has  partially  addressed  recommendation  23.  Sweden  engaged  in  regional 
cooperation  by  being  part  of  the  high-level  groups  NSEC  and  BEMIP.  Nevertheless,  in 
September 2024, Sweden decided to end its participation in NSEC. While the participation in 
the  High-Level  Groups  is  voluntary  for  Member  States,  Sweden  should  ensure  regional 
cooperation  on  energy  matters,  including  in  the  North  Sea.  Regarding  renewable  energy 
cooperation, Sweden does not provide additional information in its final plan on establishing 
the framework for cooperation on joint projects by 2025 in line with Article 9 of the revised 
RED II.   

2.11 ANALYTICAL BASIS 

Sweden  has  not  address  recommendation  20.  The  plan  provides  a  description  of  the 
analytical framework with projections reaching 2040, but does not include WAM projections, 

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which  are  essential  for  the  impact  assessment  of  the  planned  policies  and  measures.  The 
methodologies  used  are  described  and/or  referenced 
the 
recommendations provided by the Commission. The updated NECP also provides an impact 
assessment of existing policies and measures, including macro-economic impacts.   

in  detail,  according 

to 

2.12 STRATEGIC  ALIGNMENT,  COHERENCE  AND  INTERACTION  WITH  OTHER 

PLANNING INSTRUMENTS AND POLICIES 

Sweden  has  partially  addressed  recommendation  18.  The  plan  covers  most  of  the  main 
reforms  and  investments  of  the  Recovery  and  Resilience  Plan  (RRP)  that  contribute  to 
implementing the objectives, targets, and contributions. The final updated plan still does not 
refer  to  the  energy  efficiency  scheme  for  multi-dwelling  buildings  included  in  the  Swedish 
RRP,  which  aims  to  incentivise  property  owners  to  renovate  multi-dwelling  buildings;  the 
reform on streamlining the process for environmental permits included with the latest revision 
on Swedish RRP from Q4 2024; nor the inclusion of the REPowerEU chapter in the RRP.  

3  GUIDANCE  ON  THE  IMPLEMENTATION  OF  THE  NATIONAL 

ENERGY AND CLIMATE PLAN 

Sweden needs to swiftly proceed with implementing its final integrated national energy and 
climate plan. Sweden is invited to pay particular attention to the following main elements:  

•  Monitor the impacts of policies included in the plan on emission reductions under ESR, 

• 

including notably for non-CO2 emissions.  
Identify additional policies and measures to meet the LULUCF target, to be delivered by 
the Parliamentary Committee on Environmental Objectives (Miljörådsberedningen) under 
(dir. 2022:126). In defining these additional policies and measures, consider the impact of 
the projected levels of harvesting on the development of the LULUCF sink until 2030 and 
beyond.  

•  On adaptation, consider using the recently adopted new National Strategy and Action Plan 
on Adaptation to Climate Change to integrate their priorities in the implementation of the 
NECP.  Use  relevant  ongoing  local,  national  and  sectoral  processes  to  detail  their 
contribution to the different Energy Union dimensions.    

•  Clarify how it intends to phase out fossil fuel subsidies, including by developing a roadmap 

detailing the specific measures that will be taken and the timeline for phase-out.  

•  Put in place measures to achieve the higher ambition for renewables by 2030 that aligns 
with the EU’s collective target for renewable energy  given its high potential notably for 
wind  energy.  Put  in  place  a  favourable  framework  to  support  renewables-based 
electrification  across  sectors  including  increasing  awareness  amongst  citizens  and 
companies  about  financing  possibilities  and  wider  system  benefits  of  renewable  energy 
technologies.  

•  On energy  efficiency, put in  place measures to  achieve the higher ambition  for  energy 
efficiency by 2030.  Consider further energy efficiency measures targeting industry and 
transport. 

•  On buildings, ramp up the pace and depth of renovation of the building stock and put 
forward  a  complete  investment  plan  for  building  renovation,  including  the  investment 

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needs to reach the targets, the budgetary resources and the available or planned financing 
schemes.  

•  Consider  adopting  a  more  comprehensive  just  transition  strategy  that  includes  robust 
analysis of social and economic impacts and allocates appropriate financial resources. 

243