Climate Plan 2025-2035 and recommendations of the Advisory Division

Climate law requires adoption of national climate plan

The Government is obliged to adopt a climate plan at least every five years (Article 3 of the Climate Act). The climate plan sets out the climate policy to be pursued for the next ten years, aimed at the objectives set out in Article 2 of the Climate Act.

The first climate plan (Climate Plan 2021-2030) was published on 1 April 2020. This plan was based on the targets set out in the Climate Act at the time: a 95% reduction in greenhouse gas emissions by 2050 compared to 1990, an interim target of 49% reduction by 2030, and a target for 100% carbon-neutral electricity production by 2050.

In the meanwhile, the goals of the Climate Act have been raised. In accordance with Article 2(1) of the European Climate Law, the Netherlands must reduce net greenhouse gas emissions to zero by 2050 and aim for negative greenhouse gas emissions by 2050. To achieve this target by 2050, Article 2 of the Climate Act includes an interim target of 55% compared to 1990 and the target of 100% CO2-neutral electricity production by 2050.

2025-2035 Climate Plan in outline

The Climate Plan 2025-2035 (the "Climate Plan") is based on four guiding principles for the expansion of climate policy: according to the Government, climate policy must (1) lead to equitable outcomes and be explicit about what is meant by that; (2) offer economic perspective; (3) provide space for societal initiative; and (4) take into account the coherence between the transitions that must take place simultaneously to achieve climate neutrality (Chapter 1). 

Based on the main new insights from social, technological, scientific and policy developments, the Climate Plan describes the context that climate policy takes into account (Chapter 2) and then addresses the transition path to 2050 and policy directions (Chapter 3). Issues addressed include three key factors (section 3.2), climate transition in the electricity, built environment, industry, agriculture and land use, and mobility and transport sectors (section 3.3), carbon removal (section 3.4), building a circular economy and reducing chain emissions (section 3.5), and preparing for unconventional policy options, such as geo-engineering, in scenarios in which the Paris climate goals are permanently out of the picture (section 3.7). 

The effects of the Climate Plan were depicted by CE Delft in the Impact Analysis Climate Plan 2025-2035 report. The expected impacts are outlined in Chapter 4 of the Climate Plan. 

Opinion of the Division

The draft 2025-2035 Climate Plan (the "Draft Climate Plan") was submitted to the Division on 19 December 2024. The Division identifies a number of positive developments. It notes that climate policy has taken increasingly complete shape. Where, according to the Division, the 2021-2030 Climate Plan contained too few effective measures, lacked coherence between the sectors, did not adequately include the perspective on the final goal of 2050, paid little attention to consumption patterns, and allowed for insufficient involvement by market parties and citizens, the Division notes that these topics have received attention in the draft Climate Plan. The Division also notes that work has been done on a legislative programme that started in 2019 and that a separate Minister for Climate has been appointed. 

However, the draft Climate Plan also leaves many questions unanswered, according to the Divisions: among other things, the Division points to (1) the lack of a socio-economic structural analysis; (2) the importance of a coherent, consistent and predictable climate policy; (3) the setting of a legal intermediate target for 2040; (4) the need for clarity on climate justice; and (5) the lack of a behaviour change strategy. 

Below, we will address these recommendations of the Division and examine whether and to what extent the Government has adjusted the Climate Plan accordingly. 

1. The importance of socioeconomic analysis

The Division argues that the draft Climate Plan does not provide sufficient insight into what is needed for a successful transformation to an innovative and sustainable economy, and mentions the importance of a socio-economic structural analysis for mapping the strengths and weaknesses of the Dutch socio-economic structure in the long and medium-long term. According to the Division, such an analysis can form the basis for integrally considered choices and prioritisation, and thus support the government's ability to solve problems. The Division recommends that the perspective of sustainable economic growth and greater energy independence be expressly included, in addition to attention to the spatial dimensions of climate policy. Furthermore, the Division considers it important that the analysis focuses on the full breadth of the economy: on the collective, social and private sectors.

The Division refers to its opinion accompanying the 2025 Budget Memorandum and the Independent Budget Review report of 11 September 2024, in which the Division argued for a socio-economic structural analysis. The Division also refers to 2024 reports that already outline a future vision of the economy or elaborate elements for a socioeconomic structural analysis (the Perspective on Broad Prosperity in 2040 by the SER; the Moderate Growth report by the State Commission on Demographic Developments 2050). We are curious as to whether the Division has provided the Government with adequately clear pointers to conduct the analyses satisfactorily.

In a further report dated 13 March 2025, in response to the Opinion of 4 March 2025, the Government endorses the Division's call and recognises that implementation is under pressure. The government emphasises that it had already promised in a response to the 2025 State Budgetary Opinion to include the suggestion of a socio-economic analysis in the preparation for the 2026 budget. However, the Climate Plan, which the Government presented to the Upper house and the Lower House on 14 March, did not include a section on this subject. 

2. The importance of a coherent, consistent and predictable climate policy

The Division argues that a coherent policy is fundamental to achieving climate neutrality in 2050, but that the draft Climate Plan only broadly lays out the various goals and policy directions, and much further elaboration is needed. The Division also mentions that a consistent and predictable climate policy is relevant to all those involved in the climate transition and that problems may arise if it lacks predictability. The new Government's reversal of the previous Government's intention to make a (hybrid) heat pump compulsory as of 2026 when replacing a central heating boiler illustrates this, according to the Division: this change of course did not send a good signal to citizens and businesses, may lead to investments becoming unprofitable, and therefore harms willingness to invest in the future. In order to provide sufficient guidance to all those involved in the climate transition, the Division therefore recommends ensuring a coherent, consistent and predictable climate policy

In its response to the Division's opinion, the Government endorses the importance of a coherent, consistent and predictable climate policy, which is why it has opted in the draft Climate Plan not only to include a policy agenda 2025-2035, but also to describe the path toward climate neutrality in 2050. With this long-term view, the Government believes it will achieve coherent, consistent and predictable policies.

We have the impression that the Climate Plan does little to develop the coherence, consistency and predictability of climate policy even after the Division's opinion. For example, the Climate Plan includes a section in which the government states that it will look at the optimal coherence between the policy aimed at climate neutrality and circularity, and the link between circularity and other sectors, such as mobility and housing construction, but then does not elaborate on this (Climate Plan, p. 54). 

3. Recommendation for an interim target for 2040

In the draft Climate Plan, the Government has indicated that it considers the realisation of approximately 90% greenhouse gas reduction in 2040 a logical step on the way to climate neutrality in 2050, but then explicitly opts not to set a national interim target for 2040 in the national Climate Act: the Government assumes that a climate target for 2040 will be included in the European Climate Law in 2025. However, the Division stresses that setting a statutory interim target for 2040 can be of great value, as such an interim target reflects a political commitment and gives clarity to affected sectors. 

In its response to the Division’s recommendation, the Government indicated that it did not want to anticipate European decision-making with the draft Climate Plan and therefore opted not to set a national interim target for 2040. In the Climate Plan, the Government has therefore not followed the Division's recommendation. 

4. Need for clarity on climate justice

In the draft Climate Plan, the Government formulates four principles that describe what the Government believes to be an equitable climate policy and will be the starting point in climate policy in the coming years. The guiding principles are (1) achievement of climate goals; (2) shared but differentiated responsibility; (3) contribution and support according to resources; and (4) the polluter pays. 

The Division recommends that the Climate Plan further explain what these principles entail, how they relate to each other, when which principles will be used, and on the basis of what considerations and factors deviation is permitted. The Division also recommends that the principles of intergenerational and international justice be included in the plan and that a participatory strategy be developed regarding procedural justice. 

In its response to the Division's advice, the Government indicated that it would follow the advice: the Government stated that in the further elaboration it would establish indicators for each principle in order to make the principles more concrete and their implementation measurable. The government also indicated that a 'generation test' is being developed nationwide, which will be referred to in the climate plan. 

The Climate Plan added a section on the intergenerational impacts of climate policy and a section on the development of a generational test (p. 10), but did not incorporate the Division's recommendation to further explain the principles (on how these principles relate to each other and when to deviate from them). 

5. Lack of a behavioural change strategy

To achieve climate neutrality, behavioural change is essential: CE Delft's impact analysis shows that broad societal lifestyle changes, such as more sustainable consumption patterns and more efficient and circular use of energy and raw materials, can result in cost savings and in less investment in the energy system being required.

In its advice, the Division notes that the draft Climate Plan pays attention to behavioural change, but lacks a concrete strategy. The Division advises the Government to formulate a strategy, and to specify what policy the Government has in mind and what type of measures it will adopt that affect consumer and other behaviour. 

In its response to the Division's opinion, the Government indicates that the "sustainable living approach" is being developed and this approach will be explained in more detail in the draft Climate Plan. The progress of this approach will be accounted for in the annual Climate Note. The Climate Plan incorporates this on page 81. 

Other Division recommendations

Finally, the Division's opinion includes the following recommendations:

• elaborate on the choices made in the draft Climate Plan for a particular policy mix, with additional enabling and compensatory instruments included in the policy mix;
• create a climate-inclusive budget framework through a growth model;
• make timely directional choices about the development of carbon removal, and only as a secondary track alongside the primary commitment to emissions reduction; and
• further describe the enforceable measures needed to achieve full circularity in the economy by 2050.

In its response to the Division's advice, the Government indicates it will add the importance of testing whether the policy mix leads to outcomes that are equitable to the Climate Plan. Further, in its response, the Government indicates that it will create a climate-inclusive budget framework and publish a Carbon Removal Roadmap in parallel with the Climate Plan, where carbon removal policies are further substantiated and transformed into a policy agenda. Finally, in its response to the opinion, the Government indicates that it cannot provide clarity at this time on what enforceable measures are needed to achieve full circularity in the economy by 2050. 

The Climate Plan appears not to have incorporated the Division's opinions for the larger part. However, the Carbon Removal Roadmap was published simultaneously with the Climate Plan. 

Completion and where to go from here?

The Climate Plan was released just ten days after the Division's opinion of 4 March 2025. That is a short period of time. Much of the Division's advice does not appear to have been adopted or elaborated on in the Climate Plan.

The Division's recommendations are not isolated. During the Internet consultation on the draft Climate Plan, 1006 public comments were submitted, some expressing similar concerns. In addition, a letter dated 4 February 2025 to Prime Minister Schoof, drafted by the Maatschappelijke Alliantie, a broad group of environmental and other organisations, the VNG, network operators and others, emphasises the importance of stable, predictable and adequate government policy on climate and energy. This letter highlights the substantial investments in sustainable economies in surrounding countries and the need for the Netherlands not to be left behind in order to preserve important sources of prosperity, employment and a sustainable living environment.

In its response to the Division's opinion, the Government does already indicate a number of concrete measures, particularly in the area of circular economy. In addition to European measures, national measures that are being (further) developed include: 

• a circular plastic standard and a possible plastic levy; 

• measures aimed at a circular building economy; and 

• further development of the Extended Producer Responsibility.

In the Climate Plan published on 14 March 2025, however, the Government's climate policy is still left partly open, which leads to uncertainty among companies, citizens and other stakeholders. The Government may provide more clarity in the next Climate Note in October.