Opinion of the European Committee of the Regions – State of the Energy Union: getting prepared for a smooth implementation of energy transition in line with Fit for 55 targets
Date: 2025-10-14
Institutions: Commission for the Environment, Climate Change and Energy, European Committee of the Regions
Subjects: EU energy policy, carbon neutrality, energy diversification, energy efficiency, energy poverty, energy supply, energy transition, price of energy, renewable energy, security of supply








C_202506320EN.000101.fmx.xml












Official Journal of the European Union


EN
C series













C/2025/6320


3.12.2025






Opinion of the European Committee of the Regions – State of the Energy Union: getting prepared for a smooth implementation of energy transition in line with Fit for 55 targets
(C/2025/6320)














Rapporteur



:


Joško KLISOVIĆ (HR/PES), President of the Assembly of the City of Zagreb





Reference document



:


State of the Energy Union Report 2024
COM(2024) 404 12.9.2024
                  









POLICY RECOMMENDATIONS

THE EUROPEAN COMMITTEE OF THE REGIONS (COR)

Strengthening Local Implementation of the Fit for 55 Package









1.


welcomes the progress made through the Fit for 55 legislative package and the 2024 State of the Energy Union Report, which highlights achievements in renewable energy deployment, energy efficiency and energy security; nevertheless, notes with concern the persistent challenges in implementation, especially those related to permitting bottlenecks, social acceptance, the difficulty in adapting to continuous legislative changes while lacking the administrative capacity to meet new objectives and carry out plans and projects requested by other administrative bodies, regulatory fragmentation, limited technical capacity and lack of access to funding for many Local and Regional Authorities (LRAs);












2.


underlines the essential role that LRAs play in implementing the Fit for 55 package (1), noting that approximately 70 % of its provisions rely on local execution, particularly in areas such as renewable energy deployment, energy efficiency improvements, building renovation and sustainable transport systems; stresses that empowering LRAs with adequate resources, competencies and political support is key to achieving the EU’s 2030 and 2050 climate targets. Supports the EU’s ambition to achieve climate neutrality and welcomes the proposed target of 90 % reduction in greenhouse gas emissions (GHG) by 2040; underlines that this target, accompanied by the enabling conditions for citizens and industry, must be achieved by emission reductions in the EU, for which the efforts and the involvement of local and regional authorities are crucial, and in the interest of EU competitiveness and long term stability;












3.


reiterates that LRAs are not merely implementers but co-designers of the energy transition, and calls for the formal recognition of this role in EU and national legislation; underlines that Fit for 55 implementation must be adapted to local realities, taking on board factors such as the specific needs of each region, the sources of energy available, existing infrastructure and industrial and innovation capacities, the economic and social capacities of local people, and must benefit from local innovation, knowledge of territorial conditions and proximity to citizens; to this end, it is essential to guarantee enough financing and a more flexible approach to tailor policies geographically, and to ensure that projects deliver the greatest possible return for the region, taking account of how energy consumption is structured and broken down by sector and each area’s scope for renewables and industrial development;












4.


calls for the reinforcement of a structured multi-level governance model to ensure the early, continuous and meaningful involvement of LRAs in the planning, implementation and monitoring of national and EU energy policies; the Covenant of Mayors – Europe provides a well-tested methodology and platform to host such a model; urges the European Commission and Member States to fully implement Articles 10 and 11 of the Energy Union Governance Regulation, particularly with respect to the preparation of National Energy and Climate Plans (NECPs) and Social Climate Plans. A structured governance model, as promoted in the NECPlatform project (2), should ensure consistent LRA involvement in national energy policy cycles, including the preparation, implementation and revision of NECPs, building renovation strategies, plans to combat energy poverty, the just transition strategy and Social Climate Plans;












5.


recalls that LRAs which benefit from the support of local and regional energy agencies are empowered as co-designers and implementers of the energy transition. Local and regional energy agencies are non-profit organisations mandated to assist public authorities, companies and citizens in implementing sustainable energy policies and programmes, distinguished by their technology-independent approach and focus on societal benefits over commercial interests. This very specific status enables local and regional energy agencies to act as integrators of services, accelerating the scale-up of investments in the energy transition through tailored and simplified procedures for citizens, public authorities, emerging renewable energy communities and companies, ensuring the effectiveness of investments and the proper implementation of the ‘energy efficiency first’ principle laid down in Directive (EU) 2023/1791 of the European Parliament and of the Council (3) on energy efficiency, and also the implementation of new energy policies such as self-consumption, energy efficiency renovation, the fight against energy poverty and the promotion of local energy communities, identifying priorities and opportunities to improve the energy efficiency of regions;












6.


recommends the creation of an EU Action Plan supporting LRAs in creating new energy agencies (and consolidating existing ones) and one-stop shops with seed funding and technical assistance, under common criteria that help harmonise competences; such an initiative should be designed to better coordinate energy and climate policies to maximise synergies with: the Covenant of Mayors – Europe initiative, where local and regional energy agencies act as territorial coordinators and supporters of signatories – and the ManagEnergy Initiative (4), which boosts the capacity of LRAs and energy agencies to implement large scale investment programmes in energy efficiency and renewable energy at local level. The ultimate goal of this Action Plan would be to support Member States in implementing the Energy Efficiency Directive (EED), the European Performance of Buildings Directive (EPBD) and the Renewable Energy Directive (RED);












7.


recommends to explore the possibility for the European Committee of the Regions (CoR) to assume the role of a Fit for 55 Local Implementation Forum, serving as a platform to convene LRAs, national governments and EU institutions for ongoing dialogue, exchange of best practices and real-time feedback on the implementation of the Fit for 55 package;












8.


proposes that the Fit for 55 Local Implementation Forum should include a technical assistance branch and a financial matchmaking function, helping LRAs find suitable EU instruments, public-private partnerships and best practices for scaling up projects.





Enhancing Financial Support and Accessibility









9.


emphasises that the complexity and fragmentation of EU funding mechanisms continue to pose significant barriers for many LRAs, especially smaller municipalities with limited administrative capacity. Furthermore, fragmented eligibility criteria across funding sources create inefficiencies and discourage participation. Therefore, the CoR calls on the European Commission to simplify application procedures, reduce co-financing requirements and provide targeted technical assistance to improve access to the Recovery and Resilience Facility (RRF), Modernisation Fund, Cohesion Funds and the forthcoming Social Climate Fund;












10.


is concerned about the possible centralisation of EU funds through single national plans as proposed for the new MFF by the European Commission in July 2025, which steer implementation away from regions and their needs, fomenting discontent at local level and fuelling social opposition, and which do not include LRAs in the design, implementation and monitoring of the plans; in order to ensure the implementation of the Fit-for-55 package, such national plans must respect the principles of multilevel governance and partnership, as recommended by the Committee of the Regions and the Covenant of Mayors – Europe;












11.


acknowledges the European Commission’s proposal to triple the budget of the Connecting Europe Facility, which represents a significant step forward in financing the energy transition. Stresses, however, that the energy transition is not merely a technical or financial challenge, but a transformative process that requires deep engagement and ownership at the regional and local levels. In this regard, considers that the governance framework proposed in the next Multiannual Financial Framework (MFF) does not adequately reflect the need for multi-level cooperation and subsidiarity for a sustainable future. In its current form, the framework is therefore unsuitable as a basis for negotiations and must be substantially revised to strengthen the involvement of local and regional authorities in decision-making, simplify access to funds, and foster genuine partnership between all levels of governance;












12.


proposes to improve financial support for municipal Energy Transition in the context of EU cohesion policy to ensure support for LRAs and their respective local and regional energy agencies, independent of national intermediaries; proposes maintaining interregional cooperation funds, as well as those that promote energy efficiency, renewable energy and sustainability in the multi-annual financial framework, also to help finance local and regional agencies; suggests that such support schemes should prioritise projects in energy efficiency, renewable energy deployment and building renovation, sustainable mobility, green corridors and sustainable industrial processes, especially in regions facing socio-economic or infrastructural disadvantages and those suffering plant closures or relocation in the context of the energy transition and industrial decarbonisation, and be directly aimed at implementing the policy instruments of the Fit for 55 legislation;












13.


calls on the European Commission to conduct in-depth consultations with LRAs and stakeholders who benefitted from EU Technical Assistance programmes, as part of the process of rationalisation taking place in the preparation of the Multi Financial Framework 2028-2034.





Accelerating Permitting and Infrastructure Development









14.


highlights the need to accelerate the permitting process for renewable energy projects, noting that administrative delays remain one of the main obstacles to timely deployment; calls for the swift implementation of Renewables Acceleration Areas, as foreseen in the revised Renewable Energy Directive, less complex administrative procedures for energy and industrial projects, alongside the development of a harmonised EU-wide digital permitting system, to reduce bureaucracy and support faster local approvals;












15.


stresses the urgent need to increase production and supply of clean energy within the EU in order to ensure the competitiveness of EU businesses and industry, as well as the security of energy supply, energy crisis preparedness and thus energy sovereignty, while decarbonising the energy sector and simultaneously addressing energy poverty; underlines the need for the EU framework to maintain a technology-open approach based on objective assessments of life-cycle carbon footprint and societal as well as environmental and territorial impacts of different technological solutions;












16.


calls for significant investments in energy grids and in developing grids and infrastructure for new energy carriers (such as hydrogen or renewable fuels) and other carriers relevant for the energy transition (such as CO2), to improve the capacity and flexibility of electricity grids and to modernise and adapt them to the current energy mix – important not only for the energy transition but also for boosting the competitiveness of European industry – and to expand energy storage infrastructure, particularly in rural, mountainous, outermost and less-developed regions, as well as islands where grid constraints limit the integration of renewable energy and the development of decarbonised industrial projects; encourages the European Commission to prioritise support for smart grids, storage, renewable energy communities, sector coupling and decentralised energy systems;












17.


points to the work on energy carried out in the CoR on the Clean Industrial Deal, the Affordable Energy Action Plan and to its Clean Deal Going Local Working Group;












18.


stresses the strategic role of local distribution system operators (DSOs) in connecting decentralised renewable sources and facilitating energy system flexibility, and in promoting interoperability between the interfaces of DSOs and transmission system operators (TSOs); calls for stronger coordination between DSOs and LRAs in regional energy planning and grid development, as well as the facilitation of renewable energy communities; urges the sharing of relevant grid data with municipalities and their energy agencies to help identify bottlenecks and optimise investment decisions;












19.


calls for the inclusion of LRAs in regional energy grid planning bodies and in consultations for Ten-Year Network Development Plans (TYNDPs); recommends that the future grid package reflects local decarbonisation plans and includes territorial impact assessments.





Energy supply and affordability









20.


highlights the urgent need to address energy poverty in the context of rising energy prices and renovation costs. The burden of high, upfront renovation and energy efficiency costs disproportionately affects low-income and energy-poor households. Without targeted support at the local level, these groups risk being excluded from the energy transition, worsening inequality. Therefore, the CoR calls on Member States to use the Social Climate Fund and other EU instruments to prioritise vulnerable households;












21.


calls for the implementation of targeted local measures to ensure a just transition, such as zero-interest renovation loans, direct subsidies for low-income households and support for community-based energy initiatives; emphasises that such measures must be co-designed with LRAs to maximise impact and public acceptance;












22.


emphasises the importance of reskilling and upskilling the local workforce to meet the labour demands of the energy transition; calls for expanded EU and national investment in vocational training, green skills programmes, and employment incentives, particularly in regions that are energy-intensive or dependent on fossil fuel industries or facing structural labour market challenges; calls on the European Commission to include LRAs in the upcoming Union of Skills as they provide detailed data on knowledge gaps at local and regional levels from a variety of contexts. Public employment services and regional education institutions should be engaged as implementation partners for green skills development;












23.


underlines the potential for LRAs to act as facilitators, through their local and regional energy agencies, of local green labour markets and training centres in cooperation with educational institutions and local industry; calls for targeted funding and technical support for municipalities to run local green job initiatives and skills observatories.





Building Administrative and Technical Capacity









24.


acknowledges that many LRAs, particularly smaller municipalities, lack the administrative and technical capacity to implement Fit for 55 measures effectively. Effective implementation is often hindered, not only by resource constraints, but also by institutional fragmentation and limited coordination across local departments. The CoR therefore calls for a significant expansion of EU-funded technical assistance, with a central role for the ELENA facility (5) (European Local Energy Assistance) as the EU’s flagship mechanism for supporting project development at local level; also calls for improved ELENA facility conditions by making the minimum investment requirement more flexible so that even the smallest municipalities can benefit from them;












25.


emphasises that, instead of creating new knowledge platforms, priority should be given to expanding direct technical assistance and cascade funding instruments, such as the European City Facility, that enable municipalities, particularly small and medium-sized ones, to access expert support and seed financing for project development; calls for the replication and upscaling of best practices, and recommends that existing initiatives like the Covenant of Mayors and the European Climate Pact serve to link local actors with these hands-on tools and advisory services; also calls for a technical and financial advice network to be set up to ensure that resources are used as efficiently as possible and to speed up administrative procedures for sustainable energy projects;












26.


calls for the development of an EU-wide training programme for local and regional policymakers and staff, covering key areas such as energy planning, public procurement for sustainable solutions, regulatory compliance and innovative financing models; underlines the need for continuous professional development to keep pace with evolving energy and climate legislation; CINEA, through the LIFE-CET sub-programme, could provide the necessary expertise and methodology for the running of such a programme; requests that the LIFE Clean Energy Transition sub-programme be carried over into the next EU programming framework;












27.


underlines the need to build lasting local implementation capacity by reinforcing the role of local and regional energy agencies and one-stop shops,; calls for EU technical assistance programmes to prioritise support for the strengthening of existing agencies and the creation of new ones in underserved regions, so that every municipality, especially those with fewer than 50 000 inhabitants, can access expert services; recommends that energy agencies be systematically involved in training and advisory activities funded under EU programmes.





Improving Monitoring, Governance and Feedback Mechanisms









28.


proposes the introduction of a Fit for 55 Local Implementation Scoreboard, to be published annually by the European Commission, tracking progress on key indicators such as renewable energy deployment, building renovation rates, energy grid upgrades and energy poverty reduction at the local and regional levels. The scoreboard should include disaggregated indicators on local grid investment, energy poverty mitigation and the mobilisation of citizen participation in energy projects, taking advantage of the information on sustainable energy that is available in local and regional observatories;












29.


notes the European Commission’s assessment of the final updated national energy and climate plans and urges Member States to strengthen the focus on multi-level governance and involve in particular sub-national entities (local and regional authorities) in the next steps of developing the NCEPs; encourages Member States in particular to provide local-level implementation roadmaps for their updated National Energy and Climate Plans (NECPs), ensuring alignment between national targets and local Sustainable Energy and Climate Plans or similar plans at Regional level;












30.


also takes note of the Commission’s assessment that so far only a few of the national plans include information on the building and road transport sectors that could be used to prepare the Social Climate Plans, which were due by 30 June 2025. The CoR underlines the urgency of developing these plans in close cooperation with local and regional authorities in order to ensure that the Social Climate Fund will be ready to ensure a smooth and fair implementation of ETS2 and protect the most vulnerable groups and territories; is also concerned by the fact that Member States’ ambition for long term renovation strategies and the information provided on energy efficiency obligations for the public sector remain limited in most plans;












31.


highlights the need for regular and structured implementation dialogue and feedback mechanisms between LRAs, Member States and EU institutions to identify implementation challenges early and adjust policies accordingly; calls on the Commission to fully integrate the European Committee of the Regions into the implementation dialogues as a key partner;












32.


emphasises that fragmented governance and the unclear division of responsibilities between national, regional and local levels continue to hinder coherent implementation of the Fit for 55 package; calls on the EU and Member States to develop a clear coordination framework with defined roles for LRAs in each policy area under the package.





Promoting Public Engagement and Social Acceptance









33.


stresses that public support is essential for the success of the energy transition. Public opposition often stems from a lack of transparent communication and early and meaningful engagement. Efforts to foster trust must go beyond compliance and include the co-creation of solutions that address local concerns, such as landscape impact, noise and economic participation. Therefore, the CoR calls for the development of Local Stakeholder Engagement Plans for all major energy infrastructure and renovation projects, ensuring meaningful participation by citizens and community organisations;












34.


encourages the promotion of renewable energy communities and prosumer models in the forthcoming Citizen Energy Package; calls on Member States to transpose fully the Renewable Energy Directive and implement the reform of the Electricity Market Design to provide the necessary enabling frameworks for the development of renewable energy communities, with the assistance of EU dedicated support programmes;





Ensuring Policy Coherence and Competitiveness of Regions









35.


underlines the importance of aligning the energy transition with broader EU goals on sovereignty and security, social cohesion, industrial competitiveness, economic growth and regional development; calls for Fit for 55 implementation to remain a priority in the next MFF and ensure that the cohesion policy post 2027 will still be able to ensure appropriate support to local and regional authorities on their path to climate neutrality, avoiding policy fragmentation and ensuring synergies across funding programmes;












36.


highlights the positive impact of compensation to local authorities for local energy production and its impact on landscapes and other activities, also as a way to increase public support;












37.


stresses the need to ensure a level playing field for EU-based suppliers and technology providers involved in the energy transition; calls for the inclusion of sustainability, circularity and carbon footprint criteria in public procurement procedures and auctions, in line with the objectives of the Net-Zero Industry Act and the EU’s strategic autonomy goals;












38.


recommends that Member States and LRAs adopt green public procurement guidelines that incorporate life-cycle assessments, local economic benefits and social value criteria; supports the European Commission’s efforts to revise public procurement rules by recommending the provision of standardised tools and methodologies to enhance implementation and capacity-building among procurement authorities; requests that these criteria be included in aid programmes related to promoting renewables, industrial decarbonisation, new industrial activity and energy efficiency;












39.


highlights that competitiveness is inherently territorial: businesses succeed when LRAs provide the right conditions for infrastructure, development, productivity and growth; ensuring Europe’s competitiveness requires a long-term, place-based approach;












40.


calls for stronger EU action to promote circular economy principles in the energy sector, including requirements for the reuse, repowering and recycling of renewable energy infrastructure; underlines that circularity must be embedded in the entire project lifecycle, from design and procurement to decommissioning and material recovery;












41.


highlights that energy sufficiency considerations and solutions should be integrated into the relevant components of the Clean Industrial Deal as drivers for the sustainable competitiveness of EU’s industries and regions.





Conclusion









42.


concludes that the success of the Fit for 55 package depends on fully empowering LRAs as central actors in the energy transition; reiterates that overcoming existing barriers requires targeted EU support, structured governance and enhanced coordination between all levels of government. Success also depends on realistic and economically sound objectives that account for regional disparity and the practical capacities of LRAs;












43.


stresses that empowering LRAs is not only a practical necessity for achieving the EU’s climate goals, but also a democratic imperative to ensure that citizens are involved, heard and supported in the transition; underlines that only LRAs can translate broad EU objectives into socially inclusive and territorially coherent actions that build trust and ownership at the local level;












44.


calls on the European Commission to embed a local dimension in all future evaluations of energy and climate legislation, as well as the next MFF, ensuring that the implementation burden on LRAs is realistically assessed and adequately supported, and that legislation is co-created with subnational authorities from the outset;












45.


urges that the next State of the Energy Union Report include a dedicated chapter on local and regional implementation, covering good practices, data on progress at subnational level and recommendations for scaling up LRA action.






Brussels, 14 October 2025.


The President


of the European Committee of the Regions

Kata TÜTTŐ
               





(1)  European Committee of the Regions: Commission for the Environment, Climate Change and Energy, Milieu Consulting, Beamud, F., Gallego, F., Truc, M. et al., Speeding up the clean energy transition at local and regional level – The impact of the Fit for 55 package, European Committee of the Regions, 2025, https://data.europa.eu/doi/10.2863/1667526.

(2)  The NECPlatform project was launched in 2022 to support six EU Member States (Bulgaria, Croatia, France, Italy, Portugal and Romania) in setting-up and managing permanent multi-level Climate and Energy Dialogue (CED) Platforms, helping them comply with Article 11 of the Governance Regulation by fostering vertical and horizontal integration of energy and climate policies.

(3)  Directive (EU) 2023/1791 of the European Parliament and of the Council of 13 September 2023 on energy efficiency and amending Regulation (EU) 2023/955 (OJ L 231, 20.9.2023, p. 1).

(4)  
            ManagEnergy – Homepage – European Commission.

(5)  
            ELENA – European Local ENergy Assistance.


ELI: http://data.europa.eu/eli/C/2025/6320/oj
ISSN 1977-091X (electronic edition)