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Delivering the EU’s 2030 climate and energy targets: Gaps in national contributions and policies

An analysis of gaps in 22 final national energy and climate plans

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EU 2030 targets are at risk due to insufficient national contributions and policies

The analysis of 22 final updated national energy and climate plans or NECPs reveals substantial gaps that put reaching the EU 2030 targets at risk. 

Gaps are visible in 
- Member States' contributions to the EU’s renewables and energy efficiency targets;
- projected policy impacts for emissions under the Effort Sharing Regulation, natural sinks, renewables, and energy consumption; and 
- Member States' efforts to phase out fossil fuel subsidies. 

The EU needs to address these gaps. Member States should at a minimum propose their necessary contributions and develop a sufficient policy mix if the EU is to meet its targets. Ideally, this would come as part of an additional update to the final NECP, which could be requested by the European Commission as part of a closer follow-up. To improve the quality of NECPs, the EU should implement targeted changes to the Governance Regulation, which provides the relevant rules for national planning. 

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INSIGHTS FOR POLICY MAKING

Closing the contribution gaps

The shortfalls identified on renewables and energy consumption in the NECPs put the achievement of the EU’s 2030 energy targets at risk. National contributions are designed to ensure that all Member States deliver their share. Countries with contribution gaps in their NECPs should update the plans with adequate figures. 

INSIGHTS FOR POLICY MAKING

Strengthening national policies

Most Member States’ projections do not meet the respective national targets and contributions. Where this is the case, it should be highlighted and accompanied by a description of corrective measures for improving the policy mix. Our analysis highlights a particular need for enhanced energy efficiency policies. NECPs that show policy gaps should be updated with projections that include additional or revised measures that deliver the national contributions.

INSIGHTS FOR POLICY MAKING

Phasing out fossil fuel subsidies

The EU’s commitment to phase out fossil fuels cannot be achieved unless a significant set of incentives for fossil fuel use is tackled at national level. While there is some progress in phasing out direct subsidies, the analysed NECPs fail to acknowledge various indirect subsidies, which should be addressed in the same fashion. A revision of the Energy Taxation Directive would provide a common ground for all countries to remove exemptions and reduced tax rates that support and encourage the use of fossil fuels.

INSIGHTS FOR POLICY MAKING

Follow-up and targeted changes to the Governance Regulation

Closer follow-up by the European Commission on inadequate or incomplete submissions, along with a request for updates again in 2025, could help resolve the planning shortcomings. In addition, the gaps found could ultimately be addressed through targeted changes to the underlying legislation, especially the Governance Regulation, which provides the rules for NECPs, their content and the respective adoption process. A more streamlined system for tracking progress towards climate neutrality at EU-level could help provide detailed guidance to Member States on priority areas of action and could improve national planning quality and cohesion.

Member States are obliged to draw up individual national energy and climate plans (NECPs). The plans must include information on targets and contributions to the EU objectives as well as policy scenarios that outline how the Member States will develop with the current policy mix and with additional measures until 2030 and beyond. 

On 30 June 2024, the final updated NECPs were due. However, as of 15 March 2025, only 22 out of 27 final updated NECPs had been submitted to the EU Commission. This means that formal compliance with the deadlines for submitting NECPs is lacking.  

Effort Sharing Regulation 

All Member States’ NECPs include the respective binding national emission reduction target required under the ESR. Eleven countries project to reach their target with the planned policy mix. Their projected emission reductions can, however, not compensate for the gaps in the projections of the other eleven Member States. This results in an overall policy gap of around 89 Mt CO2eq and means that the EU risks missing its 2030 ESR target by nearly 2%-points, assuming that the 5 NECPs not yet submitted include projections that meet national targets.

Are the national targets mentioned in the NECPs consistent with EU law?

All Member States mention their respective binding 2030 ESR target in their NECP, with two countries exceeding expectations: Luxembourg mentions a 55% emission reduction target that is 5%-points beyond its ESR obligation, and Slovenia mentions a 28% reduction target that is 1%-point beyond requirements.

Are policy mixes projected to achieve national targets?

Half of the Member States do not reach their binding ESR target with the planned or existing policy mix according to their projections. Italy, Denmark, Cyprus, Austria, and Finland expect a gap of between 3 and 7%-points; Sweden, Germany, the Netherlands, and France of around 10%-points. Ireland expects a gap of more than 16%-points and Malta over 50%-points. In sum, this means that emission reductions of around 130 Mt CO2eq are not accounted for.

The eleven other Member States project that their planned policy mix will be sufficient to meet their 2030 target based on projections with additional or existing measures. Czechia, Portugal and Greece project an overachievement of more than around 10%-points. The other countries’ overachievement ranges from 1%-point to 7%-points. The combined projected overachievement is about 42 Mt CO2eq with the largest contribution coming from Spain with 17 Mt CO2eq. 

Nevertheless, the result in an overall gap of 89 Mt CO2eq across the 22 Member States assessed and means that the EU risks missing its 2030 ESR target by nearly 2%-points, assuming that the five NECPs not yet submitted are aligned with national obligations under the ESR and include a policy mix that is projected to meet national targets.

Natural sinks

All Member States mention their binding LULUCF target in their NECP. Eleven countries project to reach the target with the suggested policy mix, with some overachieving. A surplus of removals of around 24 Mt CO2 from these 11 countries does not, however, compensate for the gap that the eleven other Member States project with their policy mix, which is about 57 Mt CO2 in total. This means that the EU risks missing its 2030 LULUCF target by around 33 Mt CO2 or 13%, assuming that the five NECPs not yet submitted include projections that meet national targets.

Are the national targets mentioned in the NECPs consistent with EU law?

All Member States state their respective LULUCF targets in their NECPs. Most refer directly to country-specific values outlined in the Annex to the LULUCF-Regulation as the required change in net emissions between the baseline period (average 2016-2018) and 2030. Bulgaria, Hungary, and Italy refer to their absolute net emissions in 2030 considering the baseline data from the Regulation. This means that even if not mentioned explicitly, the stated LULUCF target can be calculated for these countries, which in all cases matches the required change in net emissions. However, it must be noted that if one accounts for updated baseline data from the 2024 GHG inventory submissions, these countries fail to align NECP ambition with their national LULUCF target.

Are policy mixes projected to achieve national targets?

Eleven countries expect that their planned or existing policy mix will not be sufficient to meet their national LULUCF targets. Spain and France show the largest policy gap – both countries also have the highest targets with 5.3 and 6.7 Mt CO2 additional removals in 2030 compared to the baseline, respectively. Both countries expect to miss their target by 14 Mt CO2 and 13 Mt CO2 with their policy mixes. Six of the eleven countries miss their targets by less than 2 Mt CO2. The gap across all submitted NECPs amounts to 57 Mt CO2. 
The eleven other countries project that they can reach their target with their policy mixes. Portugal overachieves its target by roughly 12 Mt CO2, followed by Austria and Denmark, each with almost 4 Mt CO2 more than is required. 
For the EU, a gap of 33 Mt CO2 remains across the 22 Member States. This means that the EU risks missing its 2030 LULUCF target by around 13%, assuming that the five NECPs not yet submitted include projections that meet national targets.

Renewable energies 

Most Member States put their renewables contribution in their NECPs, with five countries exceeding the necessary contribution and seven mentioning a contribution that is too low. Sweden does not report a figure. The policy mix is projected to be effective enough to meet the needed contribution in half of the countries. The overachievement largely compensates for the gap in the other eleven countries’ projections – though a very small shortfall remains. This means that the EU could still meet its renewables target, as long as the five NECPs not yet submitted include projections that meet the national contributions. 

Are national contributions in the NECPs sufficient?

Fourteen Member States communicate a contribution in line with the Renewable Energy Directive with Lithuania, Spain, Greece, Bulgaria, and Germany each contributing up to 6%-points more than necessary. Seven countries state a contribution that is too low with Slovenia contributing 13%-points less than necessary, followed by France (9%-points missing) and Hungary (4%-points missing). Sweden does not provide this information in its NECP. Overall, based on information provided in the NECPs, the national contributions are likely to be sufficient for the EU to achieve its 2030 renewables target. 

Are policy mixes projected to achieve national contributions?

Eleven Member States project to achieve their contributions with their planned or existing policy mix. Ten of these countries show an overachievement with Lithuania, Denmark, and Portugal displaying the largest of 11 to 19%-points. Finland expects to exactly meet its contribution. 
Eleven Member States’ projections show that they will not reach their contribution with their suggested policy mix. Slovenia, Sweden, and Luxembourg lag the furthest behind at around 9%-points. Ireland and Austria have a gap close to zero while the other six countries have a gap of around 3 to 4%-points.
Overall, the expected overachievement in ten countries nearly balances gaps in the eleven other countries leaving only a marginal shortfall. This means that the EU could still meet its renewables target, as long as the five NECPs not yet submitted include projections that meet the national necessary contributions. 
 

Energy consumption 

National contributions on energy consumption are insufficient to meet the EU target. Although most Member States include the necessary contribution to the final energy consumption target in their NECP, seven did not, resulting in an overall shortfall. For primary energy consumption, all except seven Member States presented a lower contribution than necessary. National projections with additional or existing measures highlight that the policy mix in almost all Member States is insufficient to meet the necessary energy consumption contributions despite the ‘energy efficiency first’ principle set by the EU. Only Romania can achieve both its necessary primary and final energy contributions with its planned policy mix. Luxembourg and Sweden do not provide information on the projection outcome.

Are national contributions in the NECPs sufficient?

National contributions to reducing final energy consumption are in line with the EED in fifteen countries. Seven countries provide an insufficient contribution. The shortcoming is largest for Spain in absolute terms at 5 Mtoe followed by Hungary with 2 Mtoe, with the remaining five countries falling short by less than 1 Mtoe. These countries derive their contributions from their projections. No country contributes beyond what is necessary. This means that in sum national contributions are insufficient for the EU.
 

Are policy mixes projected to achieve national contributions?

For final energy consumption, the policy gap is significant in all but four countries. Policy mixes in Portugal, Cyprus, Slovenia, and Romania are the only ones projected to be effective enough to meet the necessary national contributions – these countries, however, do not overachieve their contribution. Germany and France show the highest absolute policy gap of 31 Mtoe and 12 Mtoe, respectively, and Sweden and Denmark display the highest discrepancies relative to the necessary contribution at 33% and 24%, respectively. This means that the EU could miss its 2030 final energy consumption target by 86 Mtoe or 13%. 
 

Are national contributions in the NECPs sufficient?

Fifteen countries fall short in their contributions to reducing primary energy consumption. The largest contribution gap comes from Spain with 16 Mtoe followed by Italy with 4 Mtoe; all other countries have a gap of less than 3 Mtoe. Six countries state a contribution in line with the EED, including Finland, which mentions that its contribution would be according to the EED and references an upcoming strategy that will define the contribution. Bulgaria is the only country that provides a national contribution to reducing EU primary energy consumption that exceed expectations (by 1 Mtoe). This means that in sum national contributions are insufficient for the EU.

Are policy mixes projected to achieve national contributions?

The projections with additional or existing measures for primary energy consumption show that almost all presented policy mixes are insufficient to meet the necessary contributions, except in Bulgaria and Romania. However, overachievement in these two countries is below 1 Mtoe. Germany, France, Spain, and Italy deliver a combined policy gap of 114 Mtoe, of which Germany accounts for roughly half. Luxembourg and Sweden do not provide information on the projection outcome. The Netherlands provides a large range of projected energy levels in 2030, highlighting the high uncertainty that exists around energy consumption projections. Still, the projections show that with the current existing and planned national policy mixes, the EU is likely to miss its primary energy consumption target by around 142 Mtoe or 17%.

Phasing out fossil fuel subsidies 

Member States’ plans to phase out fossil fuel subsidies are lagging behind. Only half of the 22 NECPs available for assessment outline clear actions on track to phasing out direct subsidies for fossil fuels. For indirect subsidies, such as tax reliefs that directly or indirectly support fossil fuels, comprehensive plans are generally lacking. Seven countries plan to phase out at least some of their subsidies by 2030, but 14 countries do not provide a clear phase-out plan, including a date. Only one country, Latvia, plans to phase out all subsidies by 2030.

Are national contributions to phasing out direct fossil fuel subsidies sufficient?

Based on the assessment of the submitted NECPs, only half of the 22 Member States are well on track to phasing out direct subsidies to fossil fuels by 2025. Ten countries state that they have no direct subsidies anymore. Luxembourg states that its temporary subsidies to help households in the energy price crisis expired at the end of 2024. Latvia plans to phase out all direct subsidies by 2030. Greece and Austria provide a phase-out date at least for some fossil fuel subsidies. 
The status of direct fossil fuel subsidies and any plans for phasing them out is unclear in four NECPs: Malta, Romania, Spain, and Portugal. 
Cyprus, Ireland, Czechia, and Lithuania state that direct fossil fuel subsidies exist, but fail to outline a clear timeline or actions for phase out, including a date. Ireland still provides support to fuel and electricity bills for households.

Are national contributions to phasing out indirect fossil fuel subsidies sufficient?

The phase-out of indirect subsidies, including tax reliefs and benefits, has not happened yet in any of the countries assessed. Latvia plans to phase out all remaining indirect subsidies by 2030 at the latest. The Latvian NECP provides a description and table on national subsidies. 
Seven countries plan to phase out some of their indirect fossil fuel subsidies by 2030. This includes Austria, Finland, France, Germany, Lithuania, the Netherlands, and Portugal. This being said, Germany and Finland provide no date for the other listed subsidies. France and the Netherlands provide only examples of subsidies they want to phase out.
All other countries either (1) do not clearly describe existing indirect subsidies or (2) do not mention a phase-out date. For example, Denmark provides no information but refers to an ongoing process, in which an overview of the country’s indirect fossil subsidies is being prepared. Ireland provides a description of national subsidies but mentions no phase-out date. Italy also provides a description and refers to an ongoing process to eliminate harmful and inefficient subsidies generally. Spain recognises the need to align subsidies with climate mitigation goals but only states that no new hydrocarbon exploitation concessions will be granted. Hungary states that the country is in line with the OECD average regarding indirect subsidies but gives no further insights for assessment nor a phase-out plan. 

Four key laws to help achieve the 2030 climate target

National climate action is crucial to achieve the 2030 climate target of a net 55% greenhouse gas emission reduction. Four key EU laws have been adopted that include national targets and actions.

Key law adopted

Effort Sharing Regulation (ESR) 

Requiring Member States to reduce their GHG emissions covered by this Regulation

Key law adopted

Land Use, Land Use Change and Forestry Regulation (LULUCF-Regulation) 

Requiring Member States to enhance their natural sinks 

Key law adopted

Renewable Energy Directive (RED)

Requiring Member States to increase the share of renewables in the energy mix

Key law adopted

Energy Efficiency Directive (EED)

Requiring Member States to reduce their energy consumption. 

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