The adoption of the EU’s 2040 climate target marks a turning point in European climate and energy policy. With the headline objective agreed, the central challenge shifts from setting ambition to delivering it — in a political and geopolitical context that has fundamentally changed the terms on which delivery must be pursued and financed. This report sets out the architecture for a credible post-2030 climate and energy framework, structured around eight building blocks. Its central argument is that electrification powered by domestically generated renewable energy is not primarily a climate policy but a sovereignty strategy — and that designing the post-2030 legislative package around that insight offers a more robust political and economic foundation than the frameworks that preceded it.
Energy security as the organising principle
The war in the Middle East has once again highlighted European energy insecurity and the consequences of dependence on imported fossil fuels. US-Israeli military strikes on Iran in February 2026 and the resulting disruption of shipping through the Strait of Hormuz — through which roughly one-fifth of global oil normally transits — have pushed oil prices above $100 per barrel for the first time since 2022. Yet, Europe’s energy security crisis is not primarily a story of supply disruption; it is a story of structural dependency. Looking back to the Ukraine-crisis, between 2021 and 2024 the EU paid €930 billion more for fossil fuel imports than pre-crisis prices would have implied, and imported fossil fuels still account for 58% of EU primary energy — far more than China (24%) or India (37%).
The EU’s post-Ukraine response has been fossil fuel diversification: replacing Russian gas with US LNG and committing to $250 billion annually in US energy purchases under the July 2025 tariff deal. This is not a security strategy; it is re-concentration of risk under new geopolitical conditions, as demonstrated by Qatar’s 2024 threat to cut LNG supplies unless the EU relaxed its environmental standards.
The post-2030 framework must be built on a different premise. Electrification powered by domestic renewables backed by resilient grids is the only strategy that permanently reduces exposure to global fossil fuel markets and the geopolitical crises that disrupt them. The EU should establish a headline target to reduce the share of imported energy in final consumption to 30% by 2040, anchoring the energy security framework in electrification and renewable self-sufficiency rather than fossil fuel diversification.
Electrification as the backbone
Clean electrification must be the backbone of the post-2030 climate and energy architecture, with the Renewable Energy Directive (RED), the forthcoming Electrification Action Plan (EAP), and the Energy Efficiency Directive (EED) operating as an integrated system. RED IV is the defining legislative negotiation of this cycle. Pressure to use it as a simplification exercise — consolidating the targets into the Governance Regulation, weakening sectoral sub-targets, or effectively freezing ambition after 2030 — risks entrenching continued reliance on unsustainable biofuels in transport.
Instead, RED IV should reinforce electrification as the central pathway to decarbonisation of road transport as well as aviation and shipping where feasible: completing the phase-out of food and feed crop biofuels, strengthen the renewable electricity crediting mechanism for electric vehicle charging to make electrification the most attractive compliance route, and reserve scarce sustainable fuels for sectors where direct electrification is genuinely difficult.
Sectoral instruments — car and truck CO₂ standards, and aviation and shipping fuel mandates — must be preserved as freestanding obligations in the post-2030 framework. These instruments address structural barriers that carbon pricing alone cannot overcome, and must not be absorbed into or traded off against a wider ETS architecture.
Finance: the key to unlock electrification and energy security
The post-2030 architecture will fail without a step change in climate investment. Europe faces a significant investment cliff as NextGenerationEU and the Recovery and Resilience Facility wind down, while projections point to an annual investment deficit of €344 billion by 2030 in energy, buildings, transport and clean technology manufacturing alone. The Commission’s proposed MFF for 2028–2034 does not close this gap: the proposed 35% climate earmarking is a repackaging of existing commitments, not additional finance. Meanwhile, fossil fuel subsidies continue to grow even as electrification investment stalls. The investment gap is not primarily a problem of scale; it is a problem of architecture — fragmented grid governance, diluted budget prioritisation, and the absence of a coordinated financing framework aligned with electrification objectives.
Four priorities follow:
1. MFF should raise climate and environmental earmarking to at least 50%, eliminate fossil-related budget lines, and deploy the European Competitiveness Fund as the primary vehicle for industrial electrification — including output-based ramp-up support for cleantech manufacturing.
2. The EU Innovation Fund should evolve beyond demonstration toward large-scale deployment, with ETS revenues frontloaded to accelerate climate investment; and a Market Intermediary for E-Fuels should implement double-sided auctions for aviation and maritime e-fuels, bridging the price gap between e-fuels and fossil equivalents.
3. Governance reform must accompany financing: independent EU-level grid investment assessment, stronger cross-border planning mandates, and streamlined connection procedures to translate available capital into timely deployment. The proposed Industrial Decarbonisation Bank should provide guarantees, blended finance, and auction-based support targeted specifically at industrial and system electrification.
4. The Social Climate Fund should be understood as a core pillar of the electrification strategy — not a side social measure — and should be significantly expanded beyond 2032 to ensure vulnerable households can participate in the transition.
Strengthening national delivery beyond 2030
The Effort Sharing Regulation expires in 2030, and what replaces it will determine whether Member States retain direct political ownership of climate delivery. Carbon pricing alone is insufficient: binding national climate targets are a necessary complement, not an optional overlay.
Two broad approaches are assessed — extending the current ESR/LULUCF architecture, and moving towards economy-wide national targets. Both can, in principle, deliver the accountability that post-2030 climate governance requires. The critical design principles are the same regardless of which path is taken: targets must be binding and enforceable; sector-specific accountability must be preserved, whether through dedicated instruments or through careful overlay design; and national obligations must be clearly linked to the EU’s 2040 trajectory. The risk in the current political environment is that the push for simplification becomes a vehicle for weakening binding national commitments rather than rationalising them.
ETS1, ETS2, CBAM and national targets in synergy
The EU’s carbon architecture is most effective when its instruments operate in coordination. ETS1 will see its cap approach zero around 2040 under the current Linear Reduction Factor, but residual emissions are expected to persist, and what constitutes residual emissions are yet to be defined — a gap the post-2030 architecture must close. ETS2, applying carbon pricing to road transport and buildings from 2028, risks social backlash if not accompanied by strong structural measures.
Carbon markets must complement, not substitute for, national climate action; ETS2 revenues, including the SCF should fund structural investments in clean mobility and building renovation, as well as targeted support to protect vulnerable households from higher fuel and heating costs; and MSR reforms must balance environmental integrity with affordability.
Merging ETS1 and ETS2 would create significant social and political risks by imposing a uniform carbon price across sectors with very different cost structures and levels of social sensitivity, while removing the ability to manage price impacts separately. The CBAM must expand in step with the removal of free allocation and be actively pursued as a tool for international carbon pricing convergence.
Flexibilities, offsets and international credits
The amended European Climate Law permits international carbon credits under Article 6 of the Paris Agreement up to 5% of 1990 net GHG emissions, with a pilot period from 2031 to 2035. Used well, this flexibility could support high-integrity climate action in developing countries. Used poorly, it risks repeating the integrity failures of earlier offsetting schemes and delaying structural change at home.
Credits must complement, not substitute for, domestic emissions reductions; eligibility must be confined to genuinely residual emissions where abatement options have been exhausted; and integrity standards must be set at a level previous voluntary and compliance markets have consistently failed to reach. A centralised EU procurement framework, building on the REPowerEU joint purchasing experience, should be considered to prevent competitive pressure to accept lower-integrity credits.
A constrained and credible role for carbon removals
Carbon dioxide removals are a complement to emissions reductions, not a substitute. A firewall principle must govern the post-2030 architecture: CDR must never be integrated into compliance systems where it can replace emissions reductions — particularly while the ETS cap is still declining, which it will be throughout the 2030s. The CRCF methodologies adopted for DACCS, BECCS and biochar in February 2026 have structural flaws in additionality, biomass accounting and monitoring.
The post-2030 architecture should: maintain a strict distinction between permanent geological storage and temporary land-based sequestration; block integration of removals into ETS while the emissions cap is declining; link removals only to clearly identified residual emissions; and govern CDR through a dedicated Removal Trading Scheme operating in parallel with the ETS rather than as a compliance flexibility within it.
Non-CO₂ and international transport emissions
The EU Climate Law does not explicitly require that international aviation and shipping emissions be accounted for within Member State-level climate obligations under the 2040 target. The post-2030 architecture should close this gap, ensuring that economy-wide national targets explicitly incorporate each Member State’s share of these emissions.
Non-CO₂ aviation effects — contrails, NOx, water vapour — represent at least half of aviation’s total climate impact, yet no EU or international legislation currently regulates them. This is a material gap in the EU’s climate accounting that the post-2030 architecture must close. The Commission should maintain the automatic expansion of the MRV scheme for non-CO₂ aviation effects to full EEA+ scope in 2027 as intended, deliver a legislative proposal to address these effects under the ETS by end-2027, and adapt the European Air Traffic Management system for contrail avoidance. Most fundamentally, the European Climate Law should be amended to include a hard-edged legal obligation covering non-CO₂ aviation effects.
