NDCs 3.0: Missing the Mark on Ambition and Equity

Developed countries’ latest national climate plans (NDCs 3.0) expose a stark truth: those most responsible for the climate crisis are still refusing to lead its solution. A new analysis by Climate Action Network (CAN) International finds that every developed economy fails all three tests of a fair and 1.5°C-aligned pathway – ending fossil fuel production, delivering public climate finance, and ensuring a just and equitable transition. 

Reviewing developed countries’ NDCs against three tests, the review found that:

• instead of phasing out fossil fuels, most continue to subsidise or expand them; 
• instead of honouring finance commitments, they defer and dilute them. 
• references to “Just Transition” appear largely symbolic, stripped of the measures needed to protect workers, Indigenous Peoples, and communities on the frontline of change.

Among developed countries, the EU failed to submit their NDC on time, while the US submitted their NDC before withdrawing from the Paris Agreement. The EU and the US together account for over 40% of historical CO2 emissions. Nine other G20 countries did not submit their NDCs by the end of September: Argentina, China, India, Indonesia, Mexico, Saudi Arabia, South Africa, South Korea, and Turkey. Together with the EU, they account for half of current global emissions.

Given the glaring and alarming ambition gaps across developed and G20 countries, the report calls on leaders to agree to fix NDCs that are not in line with countries’ fair shares responsibilities. Parties must commit to this at the COP30 Leaders Summit. 

Key findings

• Climate finance remains under-delivered: Just two developed countries (Canada and the UK) specify climate finance volumes beyond 2025 but not beyond 2027, and none outline how they will meet their fair share obligations. No country commits to increasing international adaptation finance; in fact, only Japan and the UK mention adaptation finance at all. None of the NDCs reference contributing to the UNFCCC Fund for responding to Loss and Damage.
• No fossil fuel phase-out: Despite the clear mandate from the UAE COP28 decision, every fossil-fuel-producing developed country omits a timeline to end coal, oil, or gas production. Brazil and Russia, the only two other G20 countries that have submitted their NDCs, do not commit to phase out fossil fuels. None of the countries that currently provide fossil fuel subsidies have committed to phasing them out completely.  Every country plans or is considering using carbon offsets to achieve their targets and/or unproven and risky technologies such as carbon capture, utilisation, and storage, shifting the focus to reducing emissions from fossil fuel production rather than phasing out production itself..
• Just transition and adaptation measures sidelined: Though references to a just transition are present across the majority of analysed NDCs, the phrase is often mentioned only once and is not accompanied by implementation measures, the need to address inequalities, or essential concepts such as social protection, social dialogue, or decent work. For developed countries, just transition measures are too narrow, mainly focusing on skills training and green jobs. While several NDCs note consultations with Indigenous Peoples, none explicitly commit to upholding Free, Prior and Informed Consent or implementing the UN Declaration on the Rights of Indigenous Peoples. Only two countries analysed mention Loss and Damage in their NDCs (Canada and Brazil), and each only once. 

What CAN is calling for:

Heads of State from rich countries must publicly commit to submitting strengthened NDCs before COP31, in line with their fair shares and reflecting their legal obligations, including those affirmed by the recent climate action ruling by the International Court of Justice. 

These revised NDCs must implement the guidance from the first Global Stocktake in line with equity and the fair shares of each country:

• Set whole-of-economy, time-bound fossil fuel phase-out plans in line with a 1.5°C pathway and by 2040 at the latest for developed countries;
• Outline contributions to the global goals on renewable energy and energy efficiency, and measures to halt and reverse deforestation and forest degradation by 2030;
• Embed just transition and resilience-building measures that uphold human rights and enable sustainable development within planetary boundaries, while addressing inequalities both within and between countries.

In addition, developed countries should commit to providing new, additional and grant-based finance for mitigation, adaptation, loss and damage, and just transition measures, with specific details on how they plan to align with their fair shares

At COP30

Further, and aligned with the UN Secretary General, CAN asks countries to conclude COP30 with a strong global response plan to the glaring ambition and implementation gap, built on the principles of equity and CBDR-RC.

This response plan must include the following elements:

• COP30 must highlight the glaring ambition and implementation gap that lead to loss of lives, a perpetuation of injustice and destruction of ecosystems, even as it acknowledges the progress made under the Paris Agreement in terms of global trajectory of emissions and warming. Any political response to these gaps would be incomplete if planned climate action fails to center people, communities, and nature in order to deliver a just transition rooted in respect of human rights.
• COP30 must discuss, either in a formal dedicated space or through ministerial roundtables, the NDC and BTR synthesis reports.  
• Parties must agree a process to develop a schedule for transitioning away from fossil fuels in line with CBDR-RC and equity. This could be done by mandating COP30 and COP31 Presidencies to lead a process to set up a global fossil fuel phase-out roadmap.
• Just transition forms an important part of the architecture for enabling climate ambition. The JTWP must reach agreement on the principles of a just transition and establish the Belém Action Mechanism for Just Transition (BAM) to support the implementation of NDCs, among other measures.
• Climate finance is a key enabler for implementation. COP30 must bring clarity on provision of quality climate finance at scale.
• Parties, especially those representing developed countries and G20 member states, should enhance their national climate frameworks, including laws and policies, in accordance with the principles of CBDR-RC, equity and human rights in order to speed up implementation and go beyond current NDC pledges.
• The Action Agenda at COP30 should build momentum and help close the implementation gaps, presenting concrete and implementable global actions/ initiatives, including those from credible actors and non-party stakeholders, that can strengthen climate action in a measurable and accountable manner.

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Download file: http://CAN-Intl-NDC-Brief-October-2025.pdf