Overall NDC Equity Score
Aspiring
Emissions Reductions
Average
The NDC implementation will lead to major and fair reductions in GHG emissions, per historical responsibility.
Gender Justice
Exemplary
The NDC includes gender and mentions women as stakeholder who can drive change for climate action.
Youth Inclusion
Exemplary
The NDC is youth inclusive and provides strategies for long-term youth empowerment and meaningful youth inclusion.
Summary
The EU is a unique player in the climate space, with 27 countries who contribute to and negotiate climate policy as a group, submitting a joint NDC for all Member States and cooperating with Iceland and Norway for implementation. Considered a global leader in climate action through policies such as the European Green Deal, the EU leverages on being the third largest global economy to induce companies trading with the Union to adopt its standards, coined the ‘Brussels Effect’. The EU’s composition makes it a remarkable example at the international level of how democratic processes, although lengthy, can transform into ambitious political commitments.
But the EU is also a Top 20 emitter, one of the six top largest emitters and a historical emitter, accounting for an estimated 5.95% of global emissions. Following ratification of the Paris Agreement, the European Union set an initial target of at least 40% economy-wide reduction. With the European Green Deal (2019), it committed to reach climate neutrality by 2050, becoming binding in 2021 with the European Climate Law. The updated 2025 NDC, which covers a period up to 2035 and follows the 2020 NDC and 2023 update, sets as a fully unconditional commitment to achieve a net domestic reduction of at least 55% by 2030, and an indicative contribution of 66.25-72.5% by 2035 compared to 1990. The Commission is currently drafting proposals for a 90% net emissions reduction by 2040. Alarmingly, Europe is warming faster than any other regions of the world and the Mediterranean region is warming 20% faster than global average, with increasingly devastating consequences for ecosystems and local communities at every level of temperature increase.
Gender mainstreaming.The EU recognises the importance of gender justice to achieving climate goals. Its NDC explicitly frames women both as a vulnerable group and as active agents, leaders and decision-makers in climate action, with Member States increasingly recognising the necessity of gender justice nationally and empowering women to positions of greater power. Women are recognised as disproportionately affected by climate change, particularly by energy and transport poverty. But the NDC does not report binding targets or accountability mechanisms and lacks gender-disaggregated data. Women still only account for only 26.7% of members in the highest decision-making bodies, and gender is not mainstreamed across all sectoral policies. Concerning lack of mention of LGBTQIA+ people, intersectionality, and gender-based and sexual violence.
Youth inclusion. The EU NDC explicitly recognises the vulnerability of children and youth to climate change as well as their centrality as “agents of change”. It also indicates a commitment to their meaningful engagement in decision-making processes, but without established binding budgetary commitment or specific targets in the NDC to achieve this aim. Across the NDC, youth is not consistently included when relevant, such as in the adaptation strategy. Other notable gaps include the lack of an intergenerational dimension and child-sensitive commitments on access to information. The newly announced 2026 Strategy on Intergenerational Fairness could provide a step in the right direction.
Highlights
- Time-bound roadmap with escalating, legally binding and unconditional targets.
- Recognises both agency and vulnerability for gender and youth matters.
- Possible application of the Brussels Effect to the NDC to leverage its impact.
- Clear integration of biodiversity-climate nexus.
- Reiterated commitment in remaining the world’s leader in climate finance.
Lowlights
- Effort is insufficient with 2035 target being indicative and non-binding.
- Fossil fuel subsidies mentioned are considerably high, with the EU recognising this problem.
- Gender commitments are expressed in the form of non-binding aspirations, with no mention of data requirements or accountability mechanism; para 111 narrowed to three intersectionalities (does not cover all women); concerning lack of mention of LGBTQIA+ people, intersectionality, and gender-based and sexual violence. No disaggregated data.
- Youth remains insufficiently considered, lacking consideration in para 109 and with expressed measures remaining voluntary, without formal consultation or measurable budget commitments. No disaggregated data.
- Lack of proper accounting of military emissions: although not a requirement, it is an incredibly relevant structural gap for a significant arm exporter, especially considering the climate and humanitarian impacts of ongoing conflicts which disproportionately affect women and youth, and the overall contribution of military-related activities to GHG emissions.
- No new commitments for climate finance and full fossil fuel phase out.
- Not enough mention or consideration of indigenous peoples.
Key Recommendations
On emissions, the EU’s NDC 3.0 commitment to reduce net GHG emissions by at least 55% by 2030 compared to 1990 is fully unconditional and legally binding. But current efforts remain insufficient for a 1.5 trajectory, and the 2035 target remains indicative.
The EU views gender justice as central to climate goals, and recognises women both as disproportionately affected and agents of change. But commitments are phrased as aspirations, with no binding targets for representation, disaggregated data, or accountability mechanisms.
On youth, the NDC does not consistently name young people as vulnerable groups or decision-makers, with a sole reference in para 112 and no mention of youth in the list of vulnerable groups in adaptation. Consultations remain voluntary and no clear budget is established to guarantee youth engagement.
Future updates of the EU NDC will need to address these gaps and beyond, to include military emissions and an immediate phase out from fossil fuel subsidies.
For Gender Justice
- Women’s organisations shall be systematically included and consulted.
- Gender-disaggregated data.
- Participation should not be framed as aspirational but become a clear and binding target.
- Recognition of LGBTQIA+ people, intersectionality, and the link between climate change and gender-based violence (including sexual violence).
- Increased recognition of indigenous peoples.
For Youth Inclusion
- Youth must be included in para 109 of the NDC, which recognises that certain groups have different adaptive capabilities in terms of climate adaptation.
- Consultations should not be voluntary but acquire a defined role in the NDC.
- Youth should be represented in EU delegations to the UNFCCC.
- Inclusion of intergenerational equity lens in its future NDCs and related commitments.
- Increased recognition of indigenous youth.