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The EU institutions suggest “updating” the Nationally Determined Contribution (NDC) from the member states, according to requirements of the Paris Agreement by September 2025. The extended deadline allows the United Nations climate secretariat enough time to assess the collective effect of all national climate plans, relative to the targets under the Paris Agreement, before the start of the COP30 climate change conference in Belém (Brazil) in November 2025.
Background
The EU member states’ NDC are formally adopted by the Council of the EU; it is already the third NDC version which will have a time horizon for up to 2035 and is therefore linked with the EU climate target for 2040. The letter is going to be adopted as an amendment to the European Climate Law under the Ordinary Legislative Procedure.
The Nationally Determined Contributions, NDCs under the Paris Agreement on climate change have been adopted in 2015 under the United Nations Framework Convention on Climate Change (UNFCCC) and set a world-wide target of keeping global temperature increase well below 2°C, while aiming to stay below 1.5°C. Similarly to the UNFCCC, the Paris Agreement places stricter requirements on developed countries, which have a higher historical responsibility for climate change, and are therefore expected to support developing countries, under the principle of common but differentiated responsibilities and respective capabilities, in the light of different national circumstances.
The Paris Agreement lets the countries (aka, Parties in the text) set their own climate targets and formulate national climate plans; these NDCs must be submitted to the UNFCCC secretariat every five years. This bottom-up approach to target setting is in contrast to top-down approaches that put a limit on each country’s greenhouse gas (GHG) emissions, based on principles of fairness and equity. Such a top-down approach was used in the Kyoto Protocol (which set binding emissions reduction targets only for developed countries), the predecessor to the Paris Agreement.
When the Paris Agreement was adopted in 2015, the bottom-up approach was chosen because it offered the best chance to achieve broad consensus, including by developing countries and the world’s largest GHG emitters, such as China and the United States.
The Paris Agreement is based on a five-yearly ambition cycle: i.e. all Parties must submit NDCs with a 10-year horizon every five years. Every NDC must “represent a progression” beyond the Party’s previous NDC and “reflect its highest possible ambition”. Thus, in 2015, the Parties submitted only the so-called intended NDCs, which were converted into NDCs as soon as a country/Party joined the Paris Agreement.
The second round of NDCs was due in 2020 and the third round in 2025: the new NDCs should be informed by the outcome of the first global stock take under the Paris Agreement; this “global stock take decision”, was adopted by COP28 in December 2023, and noted with concern that the then-current NDCs fell short of the emissions reductions required to reach the temperature goal of the Paris Agreement.
Basically, the Paris Agreement requires that NDCs provide information necessary for clarity, transparency and understanding, including base year, implementation timeframes, scope and coverage. Developed countries should set economy-wide absolute emissions reduction targets, while developing countries may use other approaches, such as reductions in emissions intensity per unit of gross domestic product, reductions from projected “business-as-usual” emissions, or reductions in per-capita emissions. Moreover, developing countries/Parties may set conditional targets that depend on external climate finance.
More on the EU climate law in: https://www.integrin.dk/2023/05/01/european-green-and-climate-law/ and in: https://www.integrin.dk/2024/07/09/climate-change-and-the-green-deal-the-eu-at-a-cross-road/
While the Paris Agreement obliges Parties to submit and update NDCs, the NDCs –in fact- are neither legally binding nor enforceable. The Paris Agreement enhanced transparency framework ensures accountability through regular reporting and review. Parties may use international cooperation mechanisms under Article 6 of the Paris Agreement to achieve their NDCs. In this case, emissions reductions achieved in one country can be used towards the achievement of another country’s NDC, generally in exchange for climate finance.
Bottom line: the Paris Agreement rulebook, “modernized” by COP29 at the end of 2024, ensures that the claimed emissions reductions meet quality standards and promote both sustainable development and environmental integrity.
European Parliament’s ideas to update the EU’s NDCs
The European Parliament think tank prepared a document addressed to the member states’ governance (as well as the staff of the European Parliament and for all interested) as a background material to assist them in their preparatory work. The content of the document is the sole responsibility of its author(s) and any opinions expressed herein should not be taken to represent an official position of the European Parliament. Reproduction and translation for non-commercial purposes are authorised provided the source is acknowledged and the European Parliament is given a prior notice.
Additional information in the following sources: eprs@ep.europa.eu; https://eprs.in.ep.europa.eu; http://www.europarl.europa.eu/thinktank; and http://epthinktank.eu (blog)
The third round of NDCs was due on 10 February 2025, but most states/Parties, including the EU, missed the deadline: by the end of May 2025, only 22 Parties had submitted their third NDC. The UNFCCC informally extended the deadline to September 2025; this allows the UNFCCC secretariat to include them in the annual NDC synthesis report, to be released ahead of the November 2025 COP30 climate change conference.
The European Parliament resolution of 14 November 2024 on COP29 called on all Parties to include quantified economy-wide absolute, as opposed to relative, emissions reduction targets in their third NDCs.
Although EU member states are not obliged to submit separate NDCs (however, they may set more ambitious domestic targets), the EU submits a single EU-wide NDC on behalf of all Union member states. Moreover, the EU has opted for a joint implementation of its “continental NDC” in cooperation with Iceland and Norway.
The EU-wide NDC follows the climate action strategy decided by the EU Institutions and the guidance of the European Council; thus, the EU has generally sought to submit its NDC early in the process in order to play a leadership role by “signaling ambition to other Parties”.
Source and citations from: https://www.europarl.europa.eu/RegData/etudes/ATAG/2025/772893/EPRS_ATA(2025)772893_EN.pdf
The EU-wide NDC’s concept
The initial EU-wide NDC was submitted in March 2015; it turned into the first EU-NDC in October 2016 when the EU ratified the Paris Agreement. Following the guidance of the October 2014 European Council, it sets a target for 2030 to reduce domestic GHG emissions by 40 % compared with 1990 levels. The second EU NDC, submitted in December 2020, reflects the ambition of the European Green Deal, and sets a 55 % domestic net GHG emissions reduction target for 2030 compared with a 1990 baseline, following the guidance of the December 2020 European Council.
The EU updated its second NDC in October 2023 to take account of the European Climate Law and legislation adopted under the ‘fit for 55’ package. While the EU is not legally bound under the Paris Agreement to achieve its NDC, the European Climate Law sets a legally binding target with the same ambition, and the ‘fit for 55’ legislation ensures its implementation.
More in: https://www.integrin.dk/2024/11/27/emission-reduction-targets-carbon-market-rules-and-clean-investments/.
As well as in: https://www.integrin.dk/2024/04/19/modern-global-climate-agenda-and-contemporary-challenges/
Updating the EU-wide NDCs
The EU will have to update its NDC by September 2025, with targets for 2035. In parallel, the European Climate Law requires the EU to set a climate target for 2040. While the EU NDC is formally adopted by the Council, the EU climate target for 2040 will be adopted as an amendment to the European Climate Law under the EU ordinary legislative procedure. The processes are closely related, based on a common impact assessment and driven by the same political ambition.
The European Commission aims for a political agreement on the 2040 target before submitting the third NDC; however, the timeline is rather tight, as the legislative proposal for the 2040 target has been delayed from February 2024 to June-July 2025. Issues currently being discussed in relation to the 2040 target are: – the ambition level, – the role of carbon removals and – the use of flexibilities. In its impact-assessed February 2024 communication on the 2040 target, the Commission proposed a 90 % net emissions reduction target compared with a 1990 baseline.
In its resolution on COP29, the European Parliament called for separate 2040 sub-targets for gross emissions reductions, land-based removals and technological removals.
The flexibilities discussed at the EU and the member state levels include international cooperation mechanisms under Article 6 of the Paris Agreement: i.e. all of these decisions would have an impact on the 2035 target in the next EU-wide NDC; if no political agreement on the 2040 EU target is reached before September 2025, the Council would have to come to an agreement on the next EU NDC, with possible guidance from the European Council and taking into account the European Parliament’s positions.
The EU fights global climate change through domestic action and international cooperation, and has an extensive toolbox to deliver on its domestic climate targets. In addition, the EU has signed the Paris Agreement, Article 6 of which includes tools for international cooperation. This note explains the historic and potential role of international carbon credits in the EU, in light of the recent debate.
More on EU climate targets in: https://www.europarl.europa.eu/thinktank/en/document/EPRS_BRI(2025)772867