The deadline for submitting updated Nationally Determined Contributions (NDCs) under the Paris Agreement has officially passed, but the world is still waiting. As of March 17th, 2025, only 19 countries have submitted their third NDCs, although this process is crucial to overcoming the climate crisis. The situation in Eastern Europe, the Caucasus and Central Asia (EECCA) is even more alarming – not a single country in this region has fulfilled its obligations.
Why have so many countries failed to submit their updated climate action plans? What does this mean for the future of global climate policy? And how can countries that have already submitted their NDCs set the right direction for the rest of the world?
What are NDCs and what should be expected in the third round?
NDCs are documents in which countries detail their plans to reduce greenhouse gas emissions and adapt to climate change. They are the basis of the Paris Agreement, as they allow us to assess how close the world is to the goal of limiting global warming to 1.5°C.
Under the Paris Agreement, countries must update their NDCs every five years. New versions should contain more ambitious goals and measures to achieve climate neutrality. In 2025, countries are expected not only to update their NDCs to 2030 but also to add targets for 2035 for the first time.
However, by mid-March 2025, only 19 countries had fulfilled this commitment. Among the countries that have submitted their updated NDCs are both large economies and small island states. The list includes Andorra, Brazil, Ecuador, the Marshall Islands, New Zealand, the United Arab Emirates (UAE), Saint Lucia, Singapore, the United States of America, Switzerland, Uruguay, the United Kingdom, and Zimbabwe.
Meanwhile, the world’s largest economies, including the European Union, China, and India, have yet to submit updated NDCs.
As countries still prepare to submit their third-generation NDC, the expectations are higher than ever. The Global Stocktake (GST) has introduced stricter guidelines, emphasizing full coverage of all greenhouse gases and economic sectors. While the Paris Agreement initially allowed developing countries to gradually expand their commitments, GST now pushes all parties to adopt economy-wide emission reduction targets.
Beyond formal requirements, the substantive expectations for NDCs have also grown. As the global carbon budget shrinks rapidly, countries are urged to align their commitments with the 1.5°C target. The GST’s energy package explicitly calls for a phase-out of fossil fuels, tripling of renewable energy capacity, and doubling energy efficiency rates by 2030. However, the reality is that among the 13 analyzed updated NDCs, only one sets RES targets for 2030 and 2035, while the rest do not have a clear plan for the gradual phase-out of fossil fuels or both targets, and 8 NDCs do not mention RES targets at all.
Another major shift is the expectation that NDCs function as investment blueprints. Given that around 75% of NDCs already contain conditional elements dependent on external funding, NDCs 3.0 are expected to provide detailed sectoral implementation plans to attract private finance. While not entirely new, this push underscores the growing emphasis on mobilizing climate finance.
Together, these developments position NDCs 3.0 as more than just climate pledges—they are evolving into comprehensive national transition plans. Yet, their success depends on resolving long-standing tensions between developed and developing countries. While the loss and damage fund and the first GST showed moments of unity, financing remains a contested issue. Many developing nations remain skeptical of multilateral climate commitments, particularly given recent geopolitical instability. As countries finalize their NDCs, questions of fairness, historical responsibility, and funding access will once again take center stage—testing the very framework the Paris Agreement was designed to uphold.
Why are NDCs being delayed?
Delays in submitting NDCs can have different reasons, but the most common ones are
- Political instability. Climate policy is not a priority in many countries due to economic crises or conflicts.
- Lack of coordination between ministries. Climate strategies are often developed in environmental departments but must be coordinated with finance, energy, and infrastructure ministries. This slows down the process.
- Difficulty in creating a quality document. NDC is not just a statement of intent, but a detailed plan that should include scientifically based calculations, financing and monitoring mechanisms.
Delaying the submission of NDCs means that countries postpone their climate action indefinitely. This is especially dangerous in a situation where, according to the latest scientific data, the world is heading towards 2.7°C warming by the end of the century.
Brazil hosting COP30: what does it have to offer?
Brazil, which will host the next UN Climate Summit (COP30), presented its updated NDC back in November 2024. The document includes:
- Reducing greenhouse gas emissions by 59% to 67% by 2035 compared to 2005 levels.
- Expansion of social justice programs, including protection of the rights of Indigenous peoples affected by deforestation
- A clear strategy for environmental transformation, including integrating environmental, economic, and social aspects into public policy.
Brazil is an example of a country that uses its role as COP30 host to play a leading role in climate protection and fostering just transition principles. However, implementing its NDC depends on domestic and international funding.
What do we expect from the EECCA countries?
Eastern Europe, the Caucasus, and Central Asia are among the most vulnerable regions to climate change and, simultaneously, among the slowest to implement climate reforms.
There are some positive developments:
- Kazakhstan has an emissions trading system in the region.
- Armenia is actively investing in solar energy.
- Moldova and Ukraine adopted a climate law.
However, these individual efforts were not reflected in the updated NDCs—no country in the region submitted a document by the deadline.
To effectively address climate change, it is essential for EECCA countries to include in their NDCs clear sectoral emission reduction targets along with specific timeframes for achieving these objectives. A critical component of this effort involves fostering energy efficiency across various sectors. Additionally, there must be an expanded focus on utilizing renewable energy sources, such as solar and wind, with a clear plan for transitioning away from fossil fuels. Equally important is ensuring a just transition for affected communities, which includes actively supporting civil society participation in the decision-making process.
The delay in submitting the NDC undermines international efforts to combat the climate crisis. Our region cannot afford to wait. EECCA countries must act now.
