Expert Council: Need for Improvements to Climate Action Program

The Council of Experts on Climate Change has issued a statement on the Federal Government’s 2026 Climate Action Program, which was approved by the Cabinet on 25^th March. Having reviewed the documents submitted by the Federal Government, the Expert Council concludes that the 2026 Climate Protection Program does not meet the requirements set out in Section 9 of the Climate Action Act.

Subject to a more detailed review, the Expert Council considers it highly unlikely that the measures included to date will be sufficient to ensure that the climate targets are met. As the Federal Government presented extensive amendments as late as 18^th March, some of which were not entirely transparent, it was not possible to conduct a systematic and in-depth assessment of the program. Consequently, the Expert Council was only able to fulfil its statutory mandate to a limited extent.

Expert Council: climate targets are unlikely to be met.

The 2026 projection data, combined with the German government’s figures on the greenhouse gas reduction effect of the Climate Action Program, indicate that, across all sectors combined (excluding the land use sector LULUCF), the 2030 target will be slightly missed, whilst all other broader targets will be met. However, the Expert Council sees indications that the Federal Government may be significantly overestimating the actual GHG reduction effect of the 2026 Climate Action Program. Barbara Schlomann, Chair of the Expert Council, notes: “Many measures may have only a limited additional impact compared to existing instruments, such as quantity-based emissions trading systems, than calculated by the Federal Government.” At the same time, unresolved issues regarding financing, public acceptance and infrastructure could jeopardize the full realization of the greenhouse gas reductions expected by the Federal Government.

For the target year 2030, the shortfall projected by the 2026 projection data is very narrow even without the additional impact of the 2026 Climate Protection Program. Accordingly, the Expert Council cannot rule out the possibility that the 65% reduction target for 2030 – partly because of the continuing weak economic situation – might just be met. According to the 2026 projection data, the shortfall for the other targets is significantly higher in each case. “This means that considerable additional effects would need to occur in order to achieve these targets,” concludes Barbara Schlomann, adding: “Subject to further in-depth analysis, it is significantly less likely that these will materialize to the extent required than is the case for the 2030 target.” The Expert Council therefore considers it highly likely that the 88% reduction target for 2040 and the budget target for the period 2031 to 2040 will be missed, even following the implementation of the 2026 Climate Action Program. The Expert Council considers this assessment to be further supported by the fact that the weakening of important measures in the building and transport sectors has since been announced and had not yet been considered when the 2026 projection data was compiled.

According to the federal government’s calculations, even after implementing the measures set out in the climate protection program, the land use sector (LULUCF) would still fall significantly short of its reduction targets up to 2040, even if these measures were to fully take effect on the medium emissions pathway from the 2026 projection data. Council member Julia Pongratz analyses: “Although the Federal Government reports substantial GHG reduction effects for the land use sector by 2045, these are only partially plausible based on the available documentation.” Among other things, there is a lack of consistent data on the reduction effect in the legally relevant four-year periods (2027–2030, 2037–2040 and 2042–2045), meaning that a reliable assessment of target achievement is not possible. She adds: “Furthermore, there are considerable uncertainties regarding the actual reduction effect of the package of measures.”

Overall, there is little that is new

The Expert Council finds no systematic innovation in the 2026 Climate Protection Program and notes, overall, a low level of ambition and innovation. In its view, the measures are predominantly additive and do not reveal an overall concept. The Expert Council also notes the absence of comprehensive consideration of the requirements for a climate protection program that it has set out in its previous reports: “In particular, the comprehensive integration of climate protection policy into an overall political strategy, as recommended in the 2024 biennial report, is missing,” said Marc Oliver Bettzüge, Deputy Chair of the Expert Council. Furthermore, the program contains hardly any measures for the continued improvement of energy efficiency.

In terms of sectors, the focus of effort remains on the energy sector. Measures in this sector account for almost half of the program’s reported reduction effect. “In particular, the buildings sector lacks measures with a social gradation, such as those included in the package of measures for the transport sector with the new funding program for electric mobility,” explains Council member Tanja Kneiske. The Expert Council therefore sees no recognizable focus in the climate action program presented on providing relief for households on low and middle incomes, even though the urgency for social measures to support climate action policy will continue to grow.

The Federal Government has not provided the Expert Council with any information regarding the cost-effectiveness of the proposed measures. The Expert Council recommends that the Federal Government pay greater attention to this aspect and focus more strongly on innovative, incentive-based measures. Council member Allister Loder cites examples: “In addition to already established economic instruments such as auctions and the ETS and BEHG, there are other innovative instruments such as white certificates for energy efficiency or a bonus-malus system for passenger cars.” Such instruments have already been established in other EU countries, and their financing could be independent of the public budget or budget-neutral and designed to include a social component.

Limited scope for review

Due to the federal government’s drafting process, it was only possible to conduct a limited in-depth review of the 2026 Climate Action Program. Although the Expert Council had already received and commented on several draft versions of the program since January 2026, extensive changes were made at short notice to the most recently submitted version. Furthermore, in the Expert Council’s assessment, a variety of altered framework conditions, particularly due to current developments in global energy markets, further limit the reliability of the available data.

The German Council of Experts on Climate Change is an independent panel comprising five experts from various disciplines. It was appointed in September 2020 and is mandated by Sections 11 and 12 of the Climate Action Act (KSG). The council consists of the following five members: Dr Barbara Schlomann (Chair), Prof. Dr Marc Oliver Bettzüge (Deputy Chair), Prof. Dr. Dr. Tanja Kneiske, Prof. Dr Allister Loder and Prof. Dr Julia Pongratz. For more information about the Council of Experts on Climate Change and their publications, please visit https://www.expertenrat-klima.de/.