NECPs developed in 2019 have become obsolete notably after the launch of the European Green Deal and the ‘Fit for 55’ package, the COVID-19 pandemic and ‘Next Generation EU’, as well as the war in Ukraine and the ‘REPowerEU’ policy package.
The ongoing update is therefore of the utmost importance for Member States to at least align with the EU’s updated 2030 requirements, but also an opportunity to go beyond them and align with Paris Agreement commitments.

About the NECP tracker

The NECP Tracker, developed by Climate Action (CAN) Europe and SEO/BirdLife, together with the other 12 partners of the TogetherFor1.5 project, is a tool that monitors and assesses the implementation of national climate and energy policies. It has a double function: on the one hand, it looks into whether national governments are implementing their old NECPs as planned; on the other hand, it provides a visual representation of the level of ambition of the updated NECPs (where available), compared to the old ones (which are currently being implemented), and to the current level of emissions and energy use. 

The tracker currently covers 13 EU Member States: Belgium, Bulgaria, Croatia, Czechia, Denmark, Estonia, France, Germany, Hungary, Poland, Portugal, Slovenia and Spain. Through a transparent collection of data on key indicators, the tracker aims to show the importance of nationally binding climate and energy targets to monitor their implementation and levels of ambition. The selected indicators give an overview of where Member States stand in terms of implementing the old NECPs, while the new ones are being updated. Knowing where they stand in this crucial moment is important to understand the extent to which existing policies are working, and it can inform on the potential for increasing the targets in the updated NECPs. For more on how the tracker was developed, please see the methodology document. 

The availability of such data for journalists, policy makers, NGOs, other civil society actors and citizens is key to making the climate and energy transition happen in a transparent and informative way.

General findings

Below is a summary of key findings related to the 2023 edition of the NECP tracker. In particular, we have compared historical trends in greenhouse gas emissions and energy transition trajectories and compared them, where possible, with targets and trajectories towards 2030 available in the old NECPs and new draft NECP updates. Stark differences exist between Member States covered by the tool, in terms of trends and contexts, but also in terms of quality and availability of national data, which makes it difficult to draw overall conclusions. It is also worth noting that, at the time national data was extracted, several Member States had not yet submitted their new NECP updates to the European Commission.  Nonetheless, a few common outcomes seem to emerge.

1. Ambition towards 2030

• The trajectories towards 2030 provided by Member States in their new draft NECP updates – both in terms of emissions reduction and energy transition – are not in line with their international commitment under the Paris Agreement to keep global temperatures below 1.5°C. In several cases, trajectories are not even enough to meet the EU’s 2030 climate and energy targets. This trend was already identified in an NGO’s assessment of the draft NECP updates, published in October 2023, and has been confirmed by the European Commission’s assessment in December 2023.
• Despite lacking the necessary ambition to meet international and, in several cases, EU commitments, the tracker finds that the new draft NECP updates overall show some marginal improvements compared to the 2030 ambition levels of the old NECPs. 
• In particular, energy transition indicators overall show an improvement compared to the old NECPs, though in most cases such improvements are, as clearly indicated in the Commission’s assessment, not enough to provide a sufficient contribution to EU targets. Notably, primary and final energy consumption targets have only marginally improved compared to the old NECPs, for instance in countries such as Croatia, Denmark or Spain. (Overall, no country mentioned in the tracker would meet its minimum contribution to the EU targets for primary and/or final energy consumption).
• On the other hand, major issues and deficiencies were identified among the climate indicators developed by the NECP tracker, which measure greenhouse gas emission reduction pathways. This was notably the case for sectoral targets that, when available, were at times the same as or worse than in the old NECPs. In Germany, the overall target for non-ETS sectors is less ambitious than in the old NECP. In this sense, the most worrying examples are the agriculture sector, where ambition has not increased (or it has done so only very marginally) in several countries, including Croatia, Czechia, Denmark, Germany and Spain; and the waste sector, where ambition has even decreased compared to the old NECP in many countries, such as Czechia, Denmark, Germany, Hungary (and it has not increased in Croatia).
• In a few cases, the tracker reveals inconsistencies between the draft NECP updates and other relevant national legislation. Notably, in two cases ambition levels described in the NECP are lower than those described in other relevant legislation. In its draft, Germany included 2030 and 2050 targets and trajectories based on a scenario with existing measures (WEM) that does not allow it to achieve the targets set in the 2021 Federal Climate Change Act (KSG). In Denmark, where the new draft NECP only contains a WEM scenario, the net emissions target is less ambitious than in the Danish Climate Law.
• Finally, the tracker reveals that, in most cases, the new draft NECP updates do not include all climate and energy targets needed to properly plan national climate action and energy transition. This is notably the case for sectoral climate targets which, while not strictly mandatory under the Governance Regulation, are fundamental not only to assess ambition levels, but also to monitor the implementation of the policies and measures of the NECPs towards their 2030 targets. At least one sectoral greenhouse gas emissions target (including overall ETS and non-ETS) is missing in Bulgaria, Czechia, Denmark, Estonia, Germany, Hungary, Portugal and Slovenia.

2. Implementation of the old NECPs (2019-2021)

The tracker is able to compare historical data for greenhouse gas emissions and energy with the trajectories laid out in the old NECPs, drafted between 2018 and 2020. This allows users to identify in which sectors or domains policies and measures of the old NECP are working, and where they are not. This is extremely useful to identify gaps for Member States to fill in their final new NECP updates, due in June 2024.

While the lack of data is still a key factor impeding a complete assessment of the implementation of NECPs, in some cases the NECP tracker is able to show whether Member States have respected the trajectories they have laid out by themselves, notably for the years 2019-2021. Unfortunately, there are many cases in which Member States did not respect their own trajectories for one or more of those years, both in terms of greenhouse gas emissions and energy transition targets. Countries such as Denmark and Croatia were, respectively, not in line with their net and gross emission reduction trajectories. At least one sectoral climate target (including overall ETS and non-ETS) was not respected in Bulgaria, Croatia, Germany, Denmark and Poland. Bulgaria and Poland are also not in line with their final energy consumption trajectory; Denmark did not meet the planned share of renewables both in energy consumption and electricity generation. Member States must ensure that, in the final NECP update, strong policies and measures are developed to pick up the pace in the deficient sectors and domains.

On the other hand, the NECP tracker also finds that, on several occasions, Member States are overperforming compared to their old NECP trajectories. For example, the outcome of this update shows that some Member States are doing better in renewables-related targets than their own NECP projections. This clearly indicates that Member States can do much more to reduce emissions and accelerate the energy transition, and therefore should set much more ambitious climate and energy targets in the final NECP updates.

3. Consistency of data in the NECP updates

Working on the development of the tracker allowed project partners to identify several inconsistencies related to the data used in the draft NECP updates. 

• Inconsistency between historical data – In some cases, the historical data included in the draft NECP updates is inconsistent with the historical data retrieved from the European Environment Agency (EEA) or Eurostat. For instance, this was the case for some indicators in Estonia and Denmark.

• Inconsistency in scope and definitions – In several cases, the difference between the values for historical data (from the EEA and Eurostat) and for the trajectories set in the draft NECP updates is so significant that it could only be explained by a difference in scope and definitions of certain indicators. Two examples could be the draft NECP updates of Slovenia and Czechia, whose sectoral targets for energy and industry (Slovenia) and waste (Czechia) could not be compared with the historical emission reduction trajectories retrieved from the EEA.

Consistency of data is key for planning effective policies, as well as for improving the involvement of civil society in planning and decision-making processes. In their final NECP updates, but also in their 2025 NECP Progress Reports, Member States should improve the quality of their data, ensuring that it is consistent across legislation, plans, and official documentation at the national and EU level.