Europaudvalget 2025
KOM (2025) 0274
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EUROPEAN
COMMISSION
Brussels, 27.5.2025
SWD(2025) 140 final
COMMISSION STAFF WORKING DOCUMENT
Accompanying the document
Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions
EU-wide assessment of the final updated national energy and climate plans Delivering
the Union's 2030 energy and climate objectives
{COM(2025) 274 final}
EN
EN
 kom (2025) 0274 - Ingen titel
COMMISSION STAFF WORKING DOCUMENT
Accompanying the document
Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions
EU-wide assessment of the final updated national energy and climate plans Delivering
the Union's 2030 energy and climate objectives
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Table of Contents
Introduction ........................................................................................................... 3
Bulgaria ................................................................................................................. 4
Czechia ................................................................................................................ 15
Denmark .............................................................................................................. 26
Germany .............................................................................................................. 36
Ireland ................................................................................................................. 47
Greece ................................................................................................................. 57
Spain.................................................................................................................... 68
France .................................................................................................................. 79
Croatia ................................................................................................................. 90
Italy ................................................................................................................... 101
Cyprus ............................................................................................................... 112
Latvia ................................................................................................................ 121
Lithuania ........................................................................................................... 132
Luxembourg ...................................................................................................... 140
Hungary ............................................................................................................. 149
Malta ................................................................................................................. 160
Netherlands ....................................................................................................... 170
Austria ............................................................................................................... 181
Portugal ............................................................................................................. 191
Romania ............................................................................................................ 201
Slovenia ............................................................................................................. 212
Finland .............................................................................................................. 223
Sweden .............................................................................................................. 234
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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.
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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
Progress based on latest
available data
2030 national
targets and
contributions
Assessment
of 2030
ambition
level
2020
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
16.90 Mtoe
2022: +9.9%
2023: +4.9%
2
-10%
NECP:
-11.06%
2022: Reported net
removals of -9.54 Mt CO
2
eq.
-1.16 Mt CO
2
eq.
(additional
removal
target)
Insufficient
ambition
based on
projections:
A gap of
1.45Mt CO
2
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
Regulation
3
23.3%
(SHARES)
16% (target)
2023: 22.5%
34.96%
2023: 16.58 Mtoe
13.19 Mtoe
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’).
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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 recommendations
5
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.
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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 2030
7
.
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.
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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 out
8
.
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.
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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).
8
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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 CO
2
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.
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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.
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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
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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).
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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.
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•
•
•
•
•
•
•
•
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.
14
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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
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:
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
Progress based
on latest
available data
2030 national
targets and
contributions
Assessment of
2030 ambition
level
2022: -6.7%%
2023: -5.7%
12
-26%
NECP:
-35.8%
13
2022: Reported
net emissions
of 11.268 Mt
CO
2
eq.
-0.83Mt CO
2
eq. (additional
removal
target)
Insufficient
ambition,
projected gap of
0.25Mt CO2eq
Czechia’s
contribution of
30.1% is below
the 33% required
according to
the
formula set out in
Annex II of the
Governance
Regulation
14
17.3%
(SHARES)
13%
(target)
2023: 18.5%
30.1%
Primary energy
consumption
44.3
41.4Mtoe
2023: 35.49
Mtoe
29.19 Mtoe
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 MtCO
2
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’)
15
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Reference
Scenario)
Final energy consumption
25.3 Mtoe
2023: 22.61
Mtoe
20.35 Mtoe
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.
Level of electricity
interconnectivity (%)
27.5%
2024: 27.0%
15%
15
Source: Eurostat; Czechia’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 Czechia’s draft
updated NECP and provided recommendations
16
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
16
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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
CO
2
eq 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
CO
2
eq 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
CO
2
eq 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.
17
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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 CO
2
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
18
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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 Mtoe
1
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
19
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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 target
3
, 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 2030
22
,
and then decrease until 7% by 2050
23
.
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
23
Total primary energy consumption in 2030 is expected to be 1 206PJ, according to the plan.
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
20
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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 4
th
national report submitted
in 2024 in accordance with Article 14 of Directive 2011/70/EURATOM
24
.
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.
21
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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.
22
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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 Karlovarsk�½,
Ústeck�½ and Moravskoslezsk�½. 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.
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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
24
•
•
•
•
•
•
•
 kom (2025) 0274 - Ingen titel
•
•
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.
25
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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
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
Regulation
26
Binding target for
greenhouse gas (GHG)
emissions compared to
2005 under the Effort
Sharing Regulation (ESR)
(%)
2022: -23.9%
2023: -24.9%
25
-50%
Binding target for net
GHG removals under the
Regulation on Land Use,
Land Use Change and
Forestry (LULUCF)
Reported net
removals of –
0,4 Mt CO
2
eq.
in 2022
-0,4 Mt CO
2
eq. (additional
removal
target)
National
target/contribution for
renewable energy:
Share of energy from
renewable sources in gross
final consumption of
energy (%)
31.7%
(SHARES)
30.0%
(target)
2023: 44.4%
58% (for EU
42.5% target)
National contribution for
energy efficiency:
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
Primary energy
consumption
17.5 Mtoe
2023: 15.35
Mtoe
15.35 Mtoe
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’).
26
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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 recommendations
28
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.
27
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sectors represented 76.4% of the total in Denmark
30
(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 CO
2
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 CO
2
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 CO
2
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 CO
2
storage and injection
capacity and provides split by biogenic and fossil sources. The estimates for CO
2
to be captured
by 2030 are slightly more ambitious than in the draft (15.3 Mt CO
2
in the final compared to
13.7 MtCO
2
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
31
Based on EEA data.
Excluding LULUCF.
32
Compound annual growth rate.
28
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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 out
33
.
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.
29
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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
CO
2
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 includes further measures to promote the sustainable production of
biomethane/biogas.
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
30
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3030662_0032.png
line
35
with Article 4 of Directive (EU) 2023/1791 (‘EED recast’)
36
.Denmark does not include
37
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 2040
39
. 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
36
A WAM scenario is not included.
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
31
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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
32
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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.
33
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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.
34
•
•
 kom (2025) 0274 - Ingen titel
•
•
•
•
•
•
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.
35
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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
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)
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%
Reported net
removals of -4.4
Mt CO
2
eq. in
2022
-3.75 Mt CO
2
eq. (additional
removal
target)
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
Regulation
41
.
National
target/contribution for
renewable energy:
Share of energy from
renewable sources in gross
final consumption of
energy (%)
National contribution for
energy efficiency:
19.9%
(SHARES)
18%
(target)
2023: 21.6%
41% gross
final
consumption
of energy
Primary energy
consumption
276.6
Mtoe
2023: 238.93
Mtoe
193.64
Mtoe
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’)
36
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Final energy consumption
194.3
Mtoe
2023: 187.0
Mtoe
155.55 Mtoe
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.
Level of electricity
interconnectivity (%)
42
11.4%
2024: 10.6%
15%
Source: Eurostat; Germany’s 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 Germany’s draft
updated NECP and provided recommendations
43
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).
37
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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 CO
2
eq 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 CO
2
eq 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 CO
2
emissions that could be captured annually by 2030 and does not provide details
on how the captured CO
2
will be transported. In addition, Germany’s NECP lacks an estimate
of the total CO
2
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.
38
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3030662_0040.png
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
39
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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.
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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 bodies
50
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
49
Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast).
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).
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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
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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 7
th
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.
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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
CO
2
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
44
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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.
•
•
•
•
•
•
•
•
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•
•
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.
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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
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)
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%
Reported net
emissions of
7.34 MtCO
2
eq.
in 2022,
-0.63 Mt CO
2
eq. (additional
removal
target)
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
Regulation
52
National
target/contribution for
renewable energy:
Share of energy from
renewable sources in gross
final consumption of
energy (%)
National contribution for
energy efficiency:
16.2%
(SHARES)
16%
(target)
2023: 15.3%
43%
Primary energy
consumption
13.9 Mtoe
2023: 14.06
Mtoe
11.29 Mtoe
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’).
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Final energy consumption
11.7 Mtoe
2023: 12.0 Mtoe
10.45 Mtoe
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.
Level of electricity
interconnectivity (%)
53
6.6%
2024: 0%
15%
Source: Eurostat; Ireland’s updated national energy and climate plan
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 recommendations
54
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.
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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.
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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 decade
57
.
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.
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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).
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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.
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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
solution for energy payments nor timelines for the implementation of the
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.
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.
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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
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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.
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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.
•
•
•
•
•
•
•
•
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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
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:
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
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
CO
2
eq.
-1.15 Mt
CO
2
eq. (additional
removal
target)
Expected to meet
its target: a
surplus of – 1.23
Mt
CO
2
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
Regulation
62
.
20.4%
(SHARES)
17%
(target)
2023: 25.3%
43%
Primary energy
consumption
24.7 Mtoe
2023: 19.88
Mtoe
17.8 Mtoe
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, as outlined in the UNFCCC Biennial Transparency report (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’).
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Scenario) or
17.55
Mtoe (Updated
Reference
Scenario).
Final energy consumption
18.4 Mtoe
2023: 15.73
Mtoe
15.2 Mtoe
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.
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 recommendations
64
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.
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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 CO
2
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 CO
2
eq. (additional removal target) and will generate a surplus of -
1.23 Mt CO
2
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 CO
2
can be captured by 2030 (3.1 MtCO
2
for permanent storage and 0.2 MtCO
2
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
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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
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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).
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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 approach
1
. 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.
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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
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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
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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.
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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
•
•
•
•
•
•
•
•
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•
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.
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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
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:
Progress based
on latest
available data
2030 national
targets and
contributions
Assessment of
2030 ambition
level
NECP:
-44.6%
2022: -19.5%
2023: -20.9%
69
-37.7%
Reported net
removals of
-47.4 Mt CO
2
eq. in 2022
-5.3Mt CO
2
eq. (additional
removal
target)
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
Regulation
70
21.2%
(SHARES)
20%
(target)
2023: 25%
48%
13%
relative to
reference
scenario
-13.4% by 2020
43%
compared to
BAU without
measures
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)
Primary energy
consumption
123.4
Mtoe
2023: 110.1
Mtoe
98.4 Mtoe
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’).
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Final energy consumption
86.3 Mtoe
2023: 80.6 Mtoe
71.709 Mtoe
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.
Level of electricity
interconnectivity (%)
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6.5%
2024: 4.2%
15%
Source: Eurostat; and Spains’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 Spain’s draft updated
NECP and provided recommendations
72
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
73
SWD(2023) 913 final, and Commission Recommendation of 18 December 2023, C/2023/9603.
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.
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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-CO
2
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 CO
2
eq. 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
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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
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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
contribution
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. 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 year
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nor the corresponding yearly energy savings to be achieved as
required by Article 6 of EED Recast but opts for the default approach
81
. Spain sets out policies
and measures to achieve the reduction of energy consumption from public bodies and the
renovation of public buildings.
78
79
Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast).
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.
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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
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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 sector
84
. 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.
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facilitate resilient and sustainable supply chains of key net-zero components and equipment
85
.
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).
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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).
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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.
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•
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.
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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
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
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
Regulation
87
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: -23.7%
2023: -25.7%
86
-47.5%
Reported net
removals of –
18.5 Mt CO
2
eq.
in 2022
-6.69 Mt CO
2
eq. (additional
removal
target)
35%
(accompanyin
g letter to the
NECP)
41.4%
(extrapolation
of numbers
included in the
NECP)
19.1%
(SHARES)
23%
(target)
2023: 22.3%
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’).
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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.
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
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 recommendations
89
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).
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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 MtCO
2
eq 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 CO
2
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 CO
2
storage capacity started
in early 2024 and is still ongoing. The plan recognises the importance of CO
2
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.
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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.
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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 ktoe
95
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).
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energy to be 400 bn m
2
. 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
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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
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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
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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.
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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.
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•
•
•
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.
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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
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)
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%
2022: Reported
net removals of
-4,9
Mt CO
2
eq.
- 0.6Mt CO
2
eq. (additional
removal
target)
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
Regulation
99
.
National
target/contribution for
renewable energy:
Share of energy from
renewable sources in gross
final consumption of
energy (%)
National contribution for
energy efficiency:
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
HR primary
energy
consumption
contribution is
8.05 Mtoe. EED
recast Annex I
formula results:
6.83 Mtoe
HR final energy
consumption
contribution of
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’).
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5.88 Mtoe is in
line with the
national
contribution of
5.88 Mtoe
submitted by the
Commission
.
Level of electricity
interconnectivity (%)
100
HR surpasses the
EU-wide
interconnectivity
target
52.0%
2024: 36.7%
15%
Source: Eurostat; Croatia’s final updated national energy and climate plan
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 recommendations
101
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.
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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
CO
2
eq 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
CO
2
eq compared to the reference period. Moreover, considering its projections for 2030,
Croatia will still have a gap of 2 Mt CO
2
eq 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
105
Compound annual growth rate.
Compound annual growth rate.
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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
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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
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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).
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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
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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
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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
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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 CO
2
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
•
•
•
•
•
•
•
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•
•
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.
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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
Progress based
on
latest
available data
2030 national
targets and
contributions
Assessment
of
2030
ambition
level
2020
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)
2022: -20.9%
2023: -22.3%
108
-43.7%
NECP:-40.6%
-3.15 Mt
2022: Reported
net removals of
-21 Mt CO
2
eq.
CO
2
eq.
(additional
removal
target)
Insufficient
ambition:
projected gap of
9.2 Mt CO
2
eq in
2030
National
target/contribution
renewable energy:
for
20.4%
(SHARES)
17%
(target)
Share of energy from
renewable sources in gross
final
consumption
of
energy (%)
National contribution for
energy efficiency:
2023: 19.6%
39.4%
IT contribution of
39.4% is slightly
above the 39%
required
according to
the
formula set out in
Annex II of the
Governance
Regulation
109
.
Primary
consumption
energy
158.0 Mtoe
2023:
Mtoe
134.82
123.3 Mtoe
IT primary energy
consumption
contribution
is
123.3 Mtoe. EED
recast Annex I
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’).
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formula results:
112.16
Mtoe
(Reference
Scenario)
or
111.18
Mtoe
(Updated
Reference
Scenario)
.
IT final energy
consumption
contribution
of
101.70 Mtoe is not
in line with the
national
contribution
of
93.05
Mtoe
submitted by the
Commission.
IT is below the
EU-wide
interconnectivity
target.
Final energy consumption
124 Mtoe
2023:
Mtoe
108.69
101.70 Mtoe
Level
of
electricity
interconnectivity (%)
110
8.8%
2024: 5.0%
15%
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 recommendations
111
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.
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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 CO
2
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.
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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 CO
2
.
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.
2.1.5 Fossil Fuels
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
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3030662_0106.png
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
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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.
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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.
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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.
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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 CO
2
.
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.
•
•
•
•
•
•
•
•
•
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•
•
•
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.
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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
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)
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 CO
2
eq.
-0.06 Mt CO
2
eq. (additional
removal
target)
Insufficient
ambition based on
projections: a gap
of 0.02 Mt CO2
eq
Cyprus’s
contribution of
33.2% is slightly
above the 33%
required
according to
the
formula set out in
Annex II of the
Governance
Regulation
117
National
target/contribution for
renewable energy:
Share of energy from
renewable sources in gross
final consumption of
energy (%)
National contribution for
energy efficiency:
16.9%
(SHARES)
13%
(target)
2023: 20.2%
33.2%
Primary energy
consumption
2.2 Mtoe
2023: 2,52 Mtoe
2.03 Mtoe
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’)
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Reference
Scenario)
Final energy consumption
1.9 Mtoe
2023: 1.87 Mtoe
1.80 Mtoe
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.
Level of electricity
interconnectivity (%)
118
0%
2024: 0%
15%
Source: Eurostat; Cyprus’ 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 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.
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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.
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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- out
121
. 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
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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).
116
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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.
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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
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:
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)
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 CO
2
eq.
in 2022
-0.64 MT CO
2
eq. (additional
removal
target)
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
Regulation
125
.
42.1%
(SHARES)
40%
(target)
2023: 43.2%
61%
Primary energy
consumption
5.4 Mtoe
2023: 4.27 Mtoe
3.85 Mtoe
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’).
121
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Final energy consumption
4.5 Mtoe
2023: 3.90 Mtoe
3.46 Mtoe
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
Level of electricity
interconnectivity (%)
126
42.1%
2024: 67.0%
15%
Source: Eurostat; Latvia’s final updated national energy and climate plan
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 recommendations
127
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.
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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 N
2
O 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 MtCO
2
eq 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 MtCO
2
eq.) 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
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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.
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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.
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energy efficiency measure
135
. 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 savings
136
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%.
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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
•
•
•
•
•
•
•
•
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•
•
•
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
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:
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).
Progress based
on latest
available data
2030 national
targets and
contributions
Assessment of 2030
ambition level
2022: +6.2%
2023: +3.8%
137
-21%
NECP: -21.3%
2022: Reported
net removals of
- 6 Mt CO
2
eq.
-0.66 Mt CO
2
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
Regulation
138
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’).
132
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Final energy
consumption
4.3 Mtoe
2023: 5.32 Mtoe
4.4 Mtoe
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
Level of electricity
interconnectivity
(%)
139
77.0%
2024:41.0%
15%
Source: Eurostat; Lithuania’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 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 2022
143
. 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
133
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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 CO
2
emissions that could be captured annually by
2030, broken down by source for fossil fuel and biogenic CO
2
emissions. Overall, Lithuania
plans to capture 0.2 million tonnes of CO
2
emissions per year by 2030. The plan also provides
details on how the captured CO
2
will be transported, primarily via gas carriers, rail and
pipelines, with the possibility to construct a CO
2
export terminal. The plan does not identify
the overall CO
2
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.
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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
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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).
136
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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.
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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.
138
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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.
•
•
•
•
•
•
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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
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:
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
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 CO
2
eq. in 2022,
–
0.03 Mt
CO
2
eq.
(additional
removal
target)
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
Regulation
147
.
11.7%
(SHARES)
11%
(target)
2023: 14.4%
37%
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’).
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consumption
contribution is
3.18 Mtoe.
Corrected
contribution
notified by the
Commission in
March 2024: 2.8
Mt
oe.
Luxembourg´s
surpasses the EU-
wide
interconnectivity
target.
Level of electricity
interconnectivity (%)
148
55.2%
163.8%
15%
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 2030
151
), 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)
141
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6.5% per year from 2022 to 2030, in contrast to a 4.1% decline between 2015 and 2022
152
. 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 CO
2
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 CO
2
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 -0.03MtCO
2
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 CO
2
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
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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 cooling
154
. 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.
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target for 2030 for
final energy consumption.
This contribution is not in line
155
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 2030
157
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 ktoe
158
to all public
bodies, which is also disaggregated by sector. Luxembourg reports the total floor area of 1,832
m
2
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.
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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
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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 CO
2
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.
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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.
147
•
•
•
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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
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)
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%
2022: reported
net removals of
-6.8 MtCO
2
eq.
in 2022
-0.93 Mt CO
2
eq. (additional
removal
target)
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
Regulation
160
National
target/contribution for
renewable energy:
Share of energy from
renewable sources in gross
final consumption of
energy (%)
13.85%
(2020,
SHARES)
13%
(target)
2023: 17.1%
30%
National contribution for
energy efficiency:
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)
Primary energy
consumption
26.6 Mtoe
2023: 22.1 Mtoe
24.1 Mtoe
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
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
Level of electricity
interconnectivity (%)
161
35.3%
2024: 41.7%
15%
Source: Eurostat; Hungary’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 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-CO
2
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 CO
2
emissions that could be captured by 2030. It does not
include information on the development of CO
2
transport infrastructure or on the overall CO
2
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 subsidies
166
.
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.
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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
consumption
169
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.
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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 achieved
170
but does not specify if it opted for the alternative or default
approach
171
. 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 Mtoe
172
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 measures
173
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 implementation
174
. 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
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.
170
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households, as well as specific information on policies and measures addressing
decarbonisation of heating and installation of renewables in buildings.
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
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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
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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.
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•
•
•
•
•
•
•
•
•
•
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
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:
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
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%
2022: Reported
net emissions of
0.001 Mt CO
2
eq.
-0.002 Mt CO
2
eq. (additional
removal
target)
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
Regulation
176
10.7%%
(SHARES)
10%
(target)
2023: 15.1%
24.5%
Primary energy
consumption
0.8 Mtoe
2023: 0.91 Mtoe
0.964 Mtoe
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’).
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Reference
Scenario).
Final energy consumption
0.6 Mtoe
2023: 0.72 Mtoe
0.803 Mtoe
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
Level of electricity
interconnectivity (%
177
)
31.0%
2024: 39.5%
15%
Source: Eurostat; Malta’s draft 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 Malta’s draft updated
NECP and provided recommendations
178
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-
2030
183
. 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
183
Compound annual growth rate.
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
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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 financing
2
. 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).
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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 tickets
186
,
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
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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.
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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.
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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.
•
•
•
•
•
•
•
•
•
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•
Develop a more comprehensive
just transition strategy,
that includes upskilling/reskilling
measures and allocates appropriate financial resources.
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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
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
Regulation
188
.
Binding target for
greenhouse gas (GHG)
emissions compared to
2005 under the Effort
Sharing Regulation (ESR)
(%)
2022: -33.8%
2023: -34.4%
187
-48%
Binding target for net
GHG removals under the
Regulation on Land Use,
Land Use Change and
Forestry (LULUCF)
Reported net
emissions of 5.1
Mt CO
2
eq. in
2022
0.44 MtCO
2
eq. (additional
removal
target)
National
target/contribution for
renewable energy:
Share of energy from
renewable sources in gross
final consumption of
energy (%)
14%
(SHARES)
14%
(target)
2023: 17.2%
32-42%
National contribution for
energy efficiency:
NL primary
energy
consumption
contribution is
46.22 Mtoe. EED
recast Annex I
formula results:
46.21 Mtoe
(Reference
Scenario) or 45.30
Primary
consumption
energy
60.70
Mtoe
2023: 53.8
Mtoe
46.22 Mtoe
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’).
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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.
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
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 1990
193
. 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
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2.1.1 Effort Sharing Regulation
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 2030
194
), 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 0.3MtCO
2
eq. 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 MtCO
2
eq 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
195
The 2023 emissions are based on 2024 approximated inventory reports.
Based on annual reporting of final greenhouse gas inventory data (Article 26 of the Governance Regulation).
196
Compound annual growth rate
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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 MtCO
2
. The actual commercial capacity is to be further assessed. The Netherlands
aims at an annual injection capacity of 2.5 MtCO
2
per year from 2026, through the Porthos
project. For 2030, it is estimated that 10-15 Mtpa of CO
2
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
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3030662_0175.png
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 includes further measures to promote the sustainable production of
biogas/biomethane, digestate and biogenic CO2.
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
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3030662_0176.png
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 MtCO
2
-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).
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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
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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.
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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
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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 CO
2
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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•
•
•
•
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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
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
Regulation
200
.
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 CO
2
eq.
-0.88 Mt CO
2
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
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’).
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Scenario) or 24.0
Mtoe (Updated
Reference Scenario
Final energy consumption
25.1 Mtoe
2023: 24.17
Mtoe
21.59 Mtoe
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.
Level of electricity
interconnectivity (%)
201
37.6%
2024: 29.0%
15%
Source: Eurostat; Austria’s final updated national energy and climate plan
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 CO
2
eq 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
205
Total GHG excluding LULUCF. Source: Commission calculations based on the Austrian final updated NECP
Compound annual growth rate based on the ESR share of transport, sourced from EEA, whose data is aligned
with data included in the NECP.
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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 2MtCO
2
eq 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.
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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 2030
207
.
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 inhabitants
209
. 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.
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to be achieved by all public bodies
210
but it specified that it opted for a combined approach
211
.
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."
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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.
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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).
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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.
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•
•
•
•
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.
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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
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:
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)
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%
2022: Reported
net removals of
-5.93Mt CO
2
eq.
-0.97 Mt CO
2
eq. (additional
removal
target)
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
Regulation
214
34%
(SHARES)
31%
(target)
2023: 35.2%
51%
Primary energy
consumption
22.5 Mtoe
2023: 20.71
Mtoe
16.71 Mtoe
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’).
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Final energy consumption
17.4 Mtoe
2023: 17.20
Mtoe
14.37 Mtoe
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.
Level of electricity
interconnectivity (%)
215
8.08%
2024: 11.5%
15%
Source: Eurostat; Portugal’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 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 2024
217
.
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 1990
218
.
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 2030
219
), 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.
192
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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 CO
2
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.
193
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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
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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 achieved
223
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
223
Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast).
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.
195
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ESCOs
225
. 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.
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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.
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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.
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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.
199
•
•
•
•
•
•
•
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•
•
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.
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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
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:
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
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 CO
2
eq.
in 2022
-2.38 Mt CO
2
eq. (additional
removal
target)
Insufficient
ambition:
projected gap of 2
Mt CO
2
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
Regulation
227
% 24.5%
(SHARES)
24%
(target)
2022: 24.2%
2023: 25.8%
38.3%
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’).
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line with the
national
contribution of
22.5 Mtoe
submitted by the
Commission.
Level of electricity
interconnectivity (%)
228
RO has surpassed
the EU-wide
interconnectivity
target
9.3%
2024: 16.3%
15%
Source: Eurostat; Romania’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 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 2024
230
.
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).
202
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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-CO
2
emissions, namely N
2
O from agricultural soils and CH
4
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 MtCO
2
eq in 2030 compared to the reference period.
According to 2022 figures, Romania has worsened its performance by -2.2 MtCO
2
eq 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 MtCO
2
eq 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 CO
2
capture
(62 million tonnes per year, though the source is not defined), the total CO
2
transportation via
pipelines capacity in Romania (16 million tonnes per year) and the total CO
2
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.
203
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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
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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).
205
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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
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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.
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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.
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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.
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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
CH
4
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
Table 1: Summary of key objectives, targets and contributions of Slovenia’s final updated NECP
2020
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:
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)
.
Progress based
on latest
available data
2030 national
targets and
contributions
Assessment of
2030 ambition
level
Final updated NECP submitted on 6.12.2024
2022: -9.1%
2023: -15%
238
-27%
NECP:
-28.6%
2022: Reported
net removals of -
0.17 Mt CO
2
eq.
-0.21 Mt CO
2
eq. (additional
removal
target)
Sufficient
ambition based on
projections: An
overachievement
of -2.6 Mt CO
2
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
Regulation
239
20.4%
(SHARES)
17% (target)
2023: 25.1%
33%
Primary energy
consumption
7.1 Mtoe
2023: 5.9 Mtoe
5.98 Mtoe
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’).
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Final energy
consumption
5.1 Mtoe
2023: 4.48 Mtoe
4.32 Mtoe
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.
Level of electricity
interconnectivity
(%)
240
78.90%
2024: 85.46%
15%
Source: Eurostat; Slovenia’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 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 CO
2
eq 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 CO
2
eq in
comparison to the reference period. Taking into account its projections for 2030, Slovenia
projects an overachievement of -2.6 Mt CO
2
eq 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 CO
2
emissions that could be captured by 2030. The plan
does not offer information on the development of CO
2
transport infrastructure or storage
capacity. Slovenia has a ban on CO
2
storage, so the plan indicates there are no plans to capture
CO
2
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.
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. 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 Commission
245
. 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
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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).
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if Slovenia opted for alternative or default approach
2
. 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 Mtoe
3
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.
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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
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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.
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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.
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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.
221
•
•
•
•
•
•
•
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•
•
•
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.
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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
Progress based
on latest
available data
2030
national
targets and
contributio
ns
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
CO
2
eq
compared to the
2030 target
2020
Binding target for
greenhouse gas (GHG)
emissions compared to
2005 under the Effort
Sharing Regulation (ESR)
(%)
2022: -22.9%
2023: -27%
249
-50%
Binding target for net
GHG removals under the
Regulation on Land Use,
Land Use Change and
Forestry (LULUCF)
Reported net
emissionsof
4.44 Mt CO
2
eq.
in 2022
-2.89 Mt
CO
2
eq.
(additional
removal
target)
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%
Finland’s
contribution of
62% is in line with
62% gross final
the contribution
consumption of
according to
the
energy
formula set out in
Annex II of the
Governance
Regulation
250
National contribution for
energy efficiency:
Primary energy
consumption
Finland did not
provide a
primary energy
consumption
contribution.
35.9 Mtoe
2023: 31.3 Mtoe
n.a. Mtoe
251
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.
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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.
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.
252
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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 CO
2
eq 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 CO
2
eq 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 CO
2
eq 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.
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additional net removals of 2 Mt CO
2
eq 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 CO
2
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 CO
2
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
them
257
. 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.
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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
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2.3 ENERGY EFFICIENCY DIMENSION
Finland has not addressed recommendation 11.
Finland did not include
259
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 consumption
261
.
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’)
262
, 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.
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 achieved
263
. 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
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
Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast).
259
263
However, it reported the total obligation by 2030, equal to 28375 ktoe (330.8 GWh)
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of cumulative end-use energy savings. In the plan, Finland specified how the energy efficiency
first principle will be implemented. Finland specified some
264
energy efficiency financing
programmes and support schemes.
Finland has partially addressed recommendation 13.
Finland did not include an updated
ambition level
265
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.
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
264
265
The report is focused on information and communication about financing.
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.
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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
(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.
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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
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.
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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
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.
•
•
•
•
•
•
•
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•
•
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
Table 1: Summary of key objectives, targets and contributions of Sweden’s final updated NECP
2020
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)
Progress based
on latest
available data
2030 national
targets and
contributions
Assessment of
2030 ambition
level
NECP: -43.8%
However, SE is
expected to meet
the 2030 target
with ESR
flexibilities
Insufficient
ambition:
projected gap of
13.32 Mt CO
2
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
Regulation
267
.
Final updated NECP submitted on 28.06.2024
2022: -36.9%
2023: -37.8%
266
-50%
2022: Reported
net removals of
– 41Mt CO
2
eq
-3.96 Mt CO
2
eq. (additional
removal
target)
National
target/contribution for
renewable energy:
Share of energy from
renewable sources in gross
final consumption of
energy (%)
National contribution for
energy efficiency:
60.1%
(SHARES)
49%
(target)
2023: 66.4%
67%
Primary energy
consumption
43.4 Mtoe
2023: 41.41
Mtoe
41.19 Mtoe
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
266
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.
267
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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Reference
Scenario).
Final energy consumption
30.3 Mtoe
2023: 30.26
Mtoe
30.09 Mtoe
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.
Level of electricity
interconnectivity (%)
268
24.2%
2024: 12.8%
15%
Source: Eurostat; Sweden’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 Sweden’s draft
updated NECP and provided recommendations
269
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.
270
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 case
271
. Sweden projects to achieve a 43.8% reduction in ESR
268
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%.
269
SWD(2023) 923 final, and Commission Recommendation of 18 December 2023, C/2023/9613.
270
Article 14(2) of Governance Regulation.
271
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.
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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)
272
, 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 (–41MtCO
2
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 CO
2
eq 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 CO
2
eq in 2030. Under the scenario of reduced forest growth, total net removals would be
around 29 Mt CO
2
eq t, bringing the gap to the target in 2030 to around 19 Mt CO
2
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
272
Excluding LULUCF.
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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 CO
2
to be captured in the upcoming decades. By 2030, Sweden aims to
capture more than 1.5 million tonnes per year (Mtpa) of CO
2
from industrial installations and
1.2-2.2 Mtpa of CO
2
from biogenic sources. With regards to the potential for CO
2
storage,
Sweden is not expected to have a CO
2
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.
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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 2030
3
. 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’)
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. 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
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Directive (EU) 2018/2001 on the promotion of energy from renewable sources, as amended by Directive (EU)
2023/2413
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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’)
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,
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 CO
2
taxes above the levels of Energy Taxation Directive, aid for energy efficiency in single-family
houses
4
and tax deductions for building renovations
5
. 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 measures
7
to
274
Directive EU 2023/1791 on energy efficiency and amending Regulation (EU) 2023/955 (recast).
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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 CO
2
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
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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 in detail, according to the
recommendations provided by the Commission. The updated NECP also provides an impact
assessment of existing policies and measures, including macro-economic impacts.
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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•
•
•
•
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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.
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