Proposal for a Regulation (EU) XXXX amending Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action
Date: 2026-06-15
Institutions: Directorate-General for Energy, European Commission
Subjects: energy policy

EUROPEAN COMMISSION 

DIRECTORATE-GENERAL 
CLIMATE ACTION 
Directorate A – Strategy, Analysis and Planning 
CLIMA.A.3 – Climate Governance, Plans & Mainstreaming 

DIRECTORATE-GENERAL 
FOR ENERGY 
Directorate A - Energy policy: Strategy and Coordination 
ENER.A.1. - Strategy, Policy Coordination and Planning, Inter-institutional Relations 

Brussels  
CLIMA.A.3/ 
ENER.A.1/ 

FACTUAL SUMMARY REPORT 

Stakeholder consultation 
on the update of the Governance of the Energy Union and Climate Action 

Disclaimer: This document should be regarded solely as a summary of the contributions 
made  by  stakeholders  for  the  Call  for  Evidence  and  the  Open  Public  Consultation.  It 
cannot in any circumstances be regarded as the official position of the Commission or its 
services. Responses to the consultation cannot be considered as a representative sample 
of the views of the EU population.  

1. OBJECTIVE OF THE CONSULTATION  

The consultation aimed at gathering input of the public for the upcoming review of the 
Governance Regulation (EU) 2018/1999. The input will support preparation of an impact 
assessment and a legislative proposal for the review of the Regulation, scheduled for the 
last quarter of 2026. The consultation was carried out  between 18 December 2025 - 19 
March 2026.  

2. WHO REPLIED TO THE CONSULTATION 

2.1. Call for Evidence  
153 valid responses were submitted through the EU Survey portal1. 144 responses (94%) 
came  from  stakeholders  from  EU  Member  States,  and  9  responses  (6%)  came  from 
stakeholders  outside  of  the  EU2.  The  highest  number  of  responses  came  from  Belgium 
(33%, 50), followed by Germany (9%, 14), Poland (9%, 14), and France (8%, 13).  

Business associations constituted the largest share of respondents (27%, 41), followed by 
NGOs  (22%,  33),  companies/businesses  (17%,  26),  EU  citizens  (10%,  15),  and  public 
authorities  (9  %,  13).  The  remaining  25  respondents  included,  a.o.  academic/research 
institutions, trade unions, and consumer organisations. 

1  

In line with the rules for feedback and suggestions, a suitability check was conducted with no exclusions. 
All  contributions  were  reviewed  for  duplicates,  accuracy,  and  signs  of  coordinated  responses  or 
campaigns. No exact identical full-text submissions were found. 

2   CH (1), NO (1), UA (2), UK (3), AU (1), and AO (1) 

 
 
 
 
 
 
 
 
 
2.2. Public Consultation  
186 valid responses were submitted through the EU Survey portal3. 175 responses (94%) 
came from stakeholders from the EU Member States, and 11 responses (6%) came from 
stakeholders  outside  of  the  EU4.  The  highest  number  of  responses  came  from  Belgium 
(31%, 58), followed by Italy (8%, 14) and France (7%, 13). 

Business  associations  constituted  the  largest  respondent  group  (29%,  54). The  majority 
of these  associations operate in  the energy sector (37), or  in  energy  intensive  industries 
(14)  such  as  paper, chemicals,  steel,  production  of  hydrogen,  non-ferrous  metals  and 
other.  Companies/businesses4,  together  with  NGOs,  are  the  second  largest  group,  with 
23% respondents  (42) respectively. Similarly  to  business  associations,  the  majority 
(34), operate in the energy sector, with some operating in more than one sector. 13 public 
authorities (7%) replied to the OPC from 12 Member States. 

3. MAIN FINDINGS OF THE CONSULTATION 

3.1. Call for Evidence 

The  recurring  themes  and  priorities  identified  across  different  groups  of  stakeholders 
concerned: 

−  role  of  the  National  Energy  and  Climate  Plans  (NECPs)  in  supporting  reforms  and 
investments, and in identifying infrastructure needs, financing sources, and project pipelines; 

−  post-2030 targets architecture, with varying views as to whether the current energy targets 
should  be  maintained  or,  on  the  other  hand,  transformed  into  a  single  overarching  target 
complemented by flexible indicators; 

−  resilient energy systems and security, including vulnerability due to fossil fuel dependence 
and geopolitical risks, advocating for better indicators (e.g. availability of energy) and stronger 
domestic low-carbon capacity; 

−  electrification, grids and infrastructure, notably the fact that the role of electricity steadily 
grows, but it requires significant grid expansion, flexibility solutions, storage, and cross-border 
interconnections,  also  highlighting  infrastructure  bottlenecks  as  a  major  implementation 
constraint; 

− 

simplification and streamlining as regards various planning and reporting obligations under 
the governance framework. 

3.2. Public Consultation  

The public consultation’s questionnaire consisted of seven sections, summarised below. 

3.2.1. Reviewing the scope of the Governance Regulation 

The areas seen as priorities for the Regulation to have stronger focus on are energy security, 
phasing-out of fossil fuels and subsidies, coherence and synergies with other policy areas, 
and sectoral transition pathways. On the other hand, stakeholders found that increasing the 
focus on climate and water resilience, circular economy,  and material  footprint are less 
relevant for the revision. 

3  

In line with the rules for feedback and suggestions, a suitability check was conducted with no exclusions. 
All  contributions  were  reviewed  for  duplicates,  accuracy,  and  signs  of  coordinated  responses  or 
campaigns. No exact identical full-text submissions were found. 

4   CH (1), NO (2), US (3), UK (5) 

2 

 
 
3.2.2. Evolution of the post-2030 energy and climate policy framework 

Views of stakeholders varied.  Some Member States called for an integration of energy 
targets  into  a  single  target  and  better  sequencing  between  Long-Term  Strategies  and 
NECPs.  Part of business associations and industry called for a shift towards technology-
neutral  targets,  often  favouring  a  single  overarching  target  complemented  by  flexible 
indicators rather than multiple binding sub-targets. Part of the business associations and 
industry, in particular on the renewables side, and also the NGOs defended maintaining 
the 
fossil 
often 
fuel phase-out trajectories. 

combined  with 

architecture, 

explicit 

current 

targets 

Most  of  respondents  supported  complementing  the  targets  architecture  with  a  set  of 
quantitative and/or qualitative key performance indicators (KPIs) to monitor performance. 
According to the stakeholders, the KPIs should be effective, flexible, and based on existing 
official data to reflect Member State diversity and minimise administrative burden. 

Overall,  most  respondents  consider  the  framework  should  be  kept  simple,  flexible,  and 
responsive to geopolitical and economic change. 

3.2.3. Making energy and climate investments happen 

Most of the respondents, particularly from the business associations, industry and public 
authorities and most of the NGOs were of the view that NECPs must evolve into credible, 
detailed  investment  roadmaps,  identifying  infrastructure  needs,  financing  sources,  and 
project  pipelines,  and  that  there  should  be  better  linking  of  national  planning  with  EU 
funding  instruments  to  mobilise  private  capital  and  provide  investment  certainty. In 
particular,  the  respondents  supported  strengthening  the  link between  NECPs  and  the 
relevant  EU  funding  under  the  next  Multiannual  Financial  Framework.  Furthermore, 
respondents  pointed  to  the  need  to  extend  the  time  horizon  of  NECPs  to  2050  and  to 
incorporate greater flexibility into NECPs’ adoption and updates. 

Several  NGOs,  on  the  other  hand,  cautioned  against  focussing the NECPs only  on 
investments,  stressing  instead  the  need  for  clear  targets,  policy  measures,  and 
accountability frameworks. They were of the view that NECPs already contain sufficient 
requirements on investment needs and funding, but suffer from weak compliance, calling 
instead for stronger enforcement and incentives, especially by linking NECP performance 
more closely to EU funding, the European Semester and the MFF. 

3.2.4. Contributing to a more resilient energy system  

In terms of areas where  the Governance Regulation can strengthen the  resilience of the 
energy  system,  most  respondents  pointed  to  adapting  energy  infrastructure to  better 
integrate renewable energy sources, and to security and resilience of energy supplies.  

Business  associations  and  companies/businesses emphasised  the  need  to  recognise 
flexibility and system integration tools, such as storage, demand response, sector coupling 
important  addition 
and  district heating,  as  core  resilience  components. Another 
concerned multi-vector and  infrastructure  integration,  with several  respondents  calling 
for better 
together, 
covering  of electricity,  gas, hydrogen and  CO₂  networks 
including cross-border interconnections and infrastructure planning coherence. Similarly, 
several respondents stressed domestic production capacity and diversification, including 
renewables, renewable gases or decentralised systems, as key to resilience beyond import 
security alone.  

3.2.5. Streamlining the Governance framework 

There  was  a  general  agreement  among  respondents  on  the  need  for  streamlining  and 
simplification, avoiding duplication of reporting requirements, and improved coherence of 

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timelines and planning instruments, harmonised platforms and clearer indicators, although 
some  cautioned  against  deregulation.  Stakeholders  also  called  for  digitalisation  of  the 
processes, while maintaining analytical depth and comparability. Other areas regarded as 
having very high potential for a simplification included streamlining the different reporting 
cycles  and  timelines,  introducing  fully  digitalised  templates  for  NECPs,  integrating  the 
LTS into the NECPs, and increasing the reuse of data.  

3.2.6. Strengthening cooperation between and within Member States 

As  regards  different  areas  where  stronger  cooperation  between  Member  States  is 
needed, most stakeholders pointed to  infrastructure planning, permitting of cross-border 
projects, research and innovation to enhance EU and Member States competitiveness and 
greater market uptake of technologies/solutions, and security of supply and resilience.   

Public  authorities emphasised  that  cooperation  should  be  focused,  non-duplicative,  and 
targeted at improving cross-border cooperation. They also stressed prioritising exchange 
of best practices on policies and measures rather than expanding thematic scope of areas 
where cross-border cooperation should take place.   

in  which 

Regarding ways 
the Governance Regulation  can facilitate more  effective 
cooperation between Member States, most respondents pointed to expanding the scope of 
the existing high-level groups to more areas of the NECP, and to facilitating exchanges 
between Member States at sectoral level.   

3.2.7. Improving public consultation and multilevel governance  

severely 

stakeholders’  ability 

A  number  of  respondents,  especially  those  representing  NGOs  or  local  levels  of 
governance, mentioned that consultations are often too late, poorly publicised, or based on 
incomplete  drafts,  which 
influence 
limit 
outcomes. Closely linked, they stressed that it is often unclear how (or whether) feedback 
is taken into account, calling for “response-to-consultation” reports or feedback matrices 
to  improve  accountability. There  is  a  need  to  strengthen  inclusiveness  and  stakeholder 
breadth,  ensuring  systematic  involvement  of  local  and  regional  authorities,  industry, 
investors, SMEs, civil society, and vulnerable groups, often through structured multilevel 
dialogues  or sector-specific consultations. The  Regulation’s  Multilevel  Climate  and 
Energy  Dialogue (MCED)  provision  is  often  regarded  as  adequate, but  implementation 
needs to be improved.   

to 

Other  stakeholders  representing  regional  and  local  communities  frequently  emphasised 
that while cities, regions, municipalities and citizens are central implementers/actors, yet 
they are insufficiently involved. They called for a territorial dimension in NECPs, formal, 
structured involvement of subnational actors, better alignment between national plans and 
local implementation tools. 

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Electronically signed on 02/06/2026 16:49 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121