The image was created using Sora AI tools.
Five Pillars—Twenty-Seven Routes: Flaws in the EU’s Climate and Energy Strategy
Since joining the Paris Agreement, the European Union has played a leading role in the five core areas of the fight against climate change: strengthening energy security, reducing carbon dioxide emissions, improving energy efficiency, integrating the internal energy market, and promoting research, innovation, and competitiveness. Under EU regulations, all member states draft a National Energy and Climate Plan (NECP)—a strategic framework for harmonizing national energy and climate policy priorities with shared EU targets. These plans aim to fulfil the EU’s 2030 climate policy commitments by ensuring the realization of shared targets and closer coordination between member states. Below is the first article in a three-part NECP critique by the Institute for Energy Strategy.
Five Key Areas
The NECPs compiled by member states must meet only one strict structural requirement: they must cover the five main categories defined by the EU. However, their format and content lack standardization. This leads to serious issues, which can be grouped into four main categories:
1. Some NECPs formally meet the requirement of covering the five categories but fail to set measurable targets within them. Consequently, some areas receive excessive attention while other priorities slip into the background.
2. Due to the loose framework and the lack of coherence, member states’ commitments are riddled with inconsistencies. This is especially problematic for member states with high mutual energy dependence (both in terms of import and export), whose national goals should be strictly coordinated. The EU’s internal market is highly interdependent, and given its high import ratio, the effective realization of energy diversification and energy security is called into question.
3. Comparing NECPs is nearly impossible because of structural and methodological differences. Member states use disparate data sources, measurements, and units. Furthermore, most documents rely on outdated background information, often dating back to 2021. This makes it extremely difficult to assess targets against actual performance, undermining the effective implementation of shared EU strategies.
4. Most NECPs lack structural uniformity, and vary in scope and emphasis. They prioritize increasing generation capacities while neglecting consumption-side measures, even though demand-side strategies are crucial to achieving sustainability goals. This one-sided approach hinders the creation of systemic solutions that are sustainable in the long run and deepens the gaps between member states.
An Overview of the NECPs
The creation of NECPs reflects the particularities of each member state’s political and administrative system. In theory, this flexibility allows for national characteristics; in practice, it tends to reinforce disunity, sectoral fragmentation, and varying levels of quality.
These concerns are supposed to be addressed by the Regulation on the governance of the energy union and climate action, which provides a legal framework for harmonizing member states’ climate and energy policy goals. This regulation aims to mitigate information asymmetry while compelling strategic, long-term planning. It also prompts member states to formalize their contributions to EU objectives in a standardized structure. NECPs must present the steps taken to achieve decarbonization, improve energy efficiency, decrease import dependency, strengthen the internal market, and promote research and development. However, the regulation leaves ample room for organizing the planning process, deciding the actors to be involved, and determining which governmental actors can take part.
The regulation stipulated the documents’ format and introduced a mandatory cyclical planning and reporting system. Member states must review and update their NECPs every five years and submit progress reports every two years. This mechanism helps track member state performance and creates an institutional structure to gradually increase ambition, in line with the UN Paris Climate Agreement principle of progressive tightening. Consequently, member states adjusted their commitments in the 2023 update to achieve the advanced minimum target of 55% emissions reduction, consistent with the Fit for 55 legislative package.
Every member state was required to submit the first draft of its NECP to the European Commission (EC) by the end of 2018. In June 2019, the EC released detailed evaluations of each country’s plan, including critical points and recommendations. Member states were expected to take these into account and update their NECPs until the end of 2023, also considering any new climate-policy targets adopted in the meantime. In December 2023, the EC initiated infringement procedures against Bulgaria, Poland, and Austria for failing to submit their revised plans. By November 2024, ten additional member states—Belgium, Czech Republic, Estonia, Greece, Croatia, Cyprus, Malta, Portugal, Slovenia, and Slovakia—were added to this group for failing to finalize their documents. As of this writing, Poland’s finalized NECP remains missing; Belgium was the last to submit its document to the EC in October 2025.
The delays are driven by political, administrative, and institutional factors: disputes within national governments, capacity constraints in ministries, and underestimations of the time needed to process EC recommendations. These factors not only compromise member-state compliance but also disrupt the EU-level evaluation cycle. The EC is often forced to produce its EU-wide analyses with missing data, which reduces the consistency of evaluations and undermines the commission’s political and institutional credibility.
Consequently, not only do member states tend to submit their plans inconsistently, but the EC’s evaluations across the first and the second cycles also suffer from significant divergences and scheduling issues. In the first cycle, the EC published the finalized overall evaluation of the NECPs one month before releasing the comprehensive annexes on member states. In the second cycle, these were published simultaneously. Nevertheless, publication schedules are tied to the member states’ submission deadlines—which is, in some cases, delayed. As a result, member states that meet the deadline often wait longer for the evaluation, while evaluations of late submissions are less detailed and more cursory.
It is not uncommon for member states’ evaluations to be temporarily unavailable on the EC’s official website. This usually happens during updates, but the system simply displays an error message. Additionally, evaluations often contain inaccuracies in content and composition. Finland’s evaluation, for example, includes sections copied directly from Malta’s. Furthermore, in the annex, evaluations are arranged neither chronologically nor alphabetically; instead, they follow an apparently obscure system, which further complicates traceability and comparability.
The Main Problems and Deficiencies
NECPs must concurrently implement planning, reporting, and coordination functions. The planning function is intended help member states define targets and choose appropriate sectoral policy tools. This logic presupposes that national targets are aligned with EU-wide climate goals, ensuring that all levels of the implementation—including regional and local actors—are actively involved.
However, a stark gap exists between the NECPs’ intended purpose and their actual impact: these documents formally align with other national or EU planning materials, but rarely do so in practice. While NECPs are not binding, they display member-state targets and actions in a public and structured manner and are therefore used as a reference for EU-level evaluations. Beyond setting targets, NECPs can reinforce sectoral policy coherence and social participation. In many cases, however, they do not feed into actual policy decision-making and are published primarily to satisfy compliance requirements.
The submission and evaluation process for NECPs creates several scheduling and procedural issues: the preparatory cycles generally do not align with member states’ sectoral policy processes, and most member states do not comply with deadlines. According to legislative intent, NECPs should not only serve to fulfil EU reporting obligations but also serve as a guidance in member-state decision-making, support the integration of different public policy areas, and inform resource allocation.
In practice, there are substantial differences in how member states integrate NECPs into their planning, budgetary, and executive processes. Even though some member states develop their NECPs using detailed professional models and broad consultation, these practices are exceptions rather than regular procedure. In addition, NECPs frequently do not reflect the most recent sectoral policy decisions, or they remain unamended despite changes in the economic, institutional, or geopolitical environment. After submitting an NECP, member states may adopt new strategies with different priorities while the NECP remain unchanged.
One of the biggest structural challenges in the NECP system is that member states’ political commitments vary significantly in degree and quality. Commitment to achieving climate and energy policy targets cannot be measured solely by the establishment target values or submitting an NECP. Commitments are real if they rest on the simultaneous presence of ambition, legal integration, implementation capacity, institutional support, and political coherence. Where these factors are consistently present, NECPs make a substantial contribution to EU targets. Conversely, where NECPs take effect only partially (often to comply with regulations formally), they remain administrative reports and fail to fulfil their integrative role. In effect, many NECPs only comply with regulations on paper, but do not reflect genuine commitments in policy or financial planning.
Annex I of the Regulation on the governance of the energy union and climate action provides a detailed overview of the NECPs’ compulsory elements, but detailed formatting requirements alone do not ensure that the plans are strategically sound—especially when it comes to matching actions with resources. The primary goal of NECPs was to reflect the increased ambition level of the European Green Deal, the Fit for 55 package, and the REPowerEU initiative. They must be based on five compulsory pillars that encompass the Energy Union’s main elements: decarbonization, energy efficiency, energy security, energy market integration, and research and development.
NECPs must also include the financial and budgetary frameworks required for implementation; the consideration of societal impacts, with special attention to a just transition and reducing energy poverty; and mechanisms for monitoring and reporting the implementation. Because of these guidelines and the EC’s guidance, NECPs have a largely coherent structure. Still, member states frequently use different logical approaches to address the key areas. Documents remain varied in length, level of elaboration, and terminology, further complicating consistent assessments and comparisons between countries.
NECPs differ significantly in quality and in the procedures under which they were prepared. In many cases, there is a lack of adequate national coordination and social legitimacy, while flaws stemming from capacity shortages are rampant. The linguistic accessibility, translation quality, and structural consistency of the documents fall short of the requirements of a transparent and auditable EU document system. The current structural and substantive shortcomings are not adequate to provide actual strategic guidance or to make a significant impact on member states’ policies.
Notably, member states do not have the same level of analytical, modelling, and administrative capacity. While some countries develop their documents involving specialized research institutions, ministerial background agencies, and political advisory committees, others rely on a small number of ministerial expert groups, many times with limited access to data and the latest modelling tools.
This difference significantly affects the reliability of emissions projections, energy models, and impact assessments. If these calculations are not methodologically sound, NECPs cannot live up to their key function: providing a clear and accountable explanation of how policy tools are linked to targets. Even though the EC has assembled templates, guidelines, and benchmarks, member states are not obliged to use them. Moreover, smaller member states often lack the resources and time to adapt them. Taken together, these factors can lead to structural imbalances in the evaluability and in the comparability of the documents.
Apart from substantial and structural shortcomings, NECPs also have stylistic issues, especially in their wording and English translation. A prerequisite for EU-level evaluation and comparison is English translations that use technically sound and consistent terminology. By contrast, the EC’s website states that many NECPs were produced using machine translation without professional proofreading. This practice led to recurring inaccuracies. The Polish NECP draft is a perfect example of these problems. In this case, even the table of contents contains incomplete translations: the English chapters titles are missing, and many figures become difficult to interpret because of machine-translated labels and headings.
The creation of the NECPs was a clear milestone for EU climate and energy policy coordination; however the 2019 and 2024 submission cycles, as well as the 2020 and 2025 evaluation cycles, have highlighted that the current system is insufficient to fulfil its fundamental function. NECPs attempt to serve numerous functions simultaneously, which inevitably dilutes their purpose and reduces effectiveness. By contrast, a clear, unified, harmonized, and coherent EU climate and energy strategy requires unambiguous roles, a uniform methodology, and consistently high professional quality.
