The Paris Agreement’s official oversight body is set to decide this month how to deal with over 60 countries that have still not submitted updated national climate plans, over a year after the deadline.
Composed of 12 experts from different regions of the world, the little-known Paris Agreement Implementation and Compliance Committee (PAICC) is tasked with ensuring that nations respect their obligations under the landmark 2015 climate accord.
The Paris Agreement requires each signatory government to submit climate plans known as nationally determined contributions (NDCs), setting out how they will help limit global warming to 1.5C above pre-industrial levels.
Governments also agreed in Paris that NDCs should be updated every five years and submitted 9–12 months before the next UN climate summit. For COP30, that deadline was 10 February 2025. But, over a year after that deadline, sixty-two countries have not yet produced an updated NDC including significant emitters like India, Vietnam, Argentina and Egypt.
PAICC cannot punish countries, but it can publicly reprimand them for their failure to file new NDCs and other transparency reports and ask them to explain themselves.
Concern over lack of responses
After the overwhelming majority of nations missed the February 2025 deadline to submit their NDCs, PAICC opened over 170 separate cases to engage with governments on why they had not yet issued a climate plan and what steps they were taking to address the delay. Cases are closed once countries submit their NDCs.
While the majority of countries responded to the panel’s enquiries, the PAICC’s annual report said that over 45 nations had failed to provide any information by October 2025. This raised the committee’s concern.
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A PAICC member who did not wish to be named told Climate Home News that, while efforts to maintain an open dialogue will continue, the committee will now also discuss how to proceed further with countries that remain out of step with their commitments under the Paris Agreement. The committee will hold a meeting in the German city of Bonn, home to the UN climate change body, between 24-27 March.
“This is a new era, so every step we take we do it for the first time,” they said, adding that the actions the committee will take may vary from country to country, taking into account their individual circumstances.
Deciding next steps
Governments defined the committee’s mandate at COP24 in Katowice, Poland, in 2018 and produced a list of “appropriate measures” it can take to promote compliance with the Paris Agreement. Those include helping countries access technical help or finance, recommending the development of an action plan or “issuing findings of fact” when a country fails to submit an NDC.
The PAICC member said the committee still needs to determine exactly what the last option means in practice, but it will likely take the form of a public statement identifying countries that have failed to comply. The panel could potentially take other actions beyond those listed in its mandate as long as they are not punitive or adversarial.
“The legal obligations [of the Paris Agreement] are few and far between, so it is even more important to keep tabs on whether countries respect them,” the PAICC member added.
Andreas Sieber, head of political strategy at campaigning group 350.org, said national climate plans are “the currency of the Paris Agreement and how the world tracks progress and how countries plan their transitions”.
“Countries, especially the largest emitters, must honour their obligations under the Paris Agreement and submit credible NDCs,” he told Climate Home News, adding that the same applies to wealthy nations that have pledged climate finance.
Many reasons for delays
Many of the governments that have not yet submitted NDCs are low-emitting small or poorer nations, especially in Africa. But major economies that have not issued an updated climate plan – some of which also have energy transition deals with donors – include Egypt, the Philippines and Vietnam.
Countries without a new NDC contribute to 22% of global greenhouse gas emissions, according to data compiled by ClimateWatch.
In their discussions with PAICC over the past year, countries have cited a range of reasons for the delays, including financial constraints, technical challenges, limited data, changes in government, political instability and armed conflicts, according to the committee’s annual report.
India is the largest emitter without an NDC. At COP30 last November, the Indian government said that it would submit its climate plan “on time”, with environment minister Bhupender Yadav telling reporters it would be delivered “by December”. But that self-imposed deadline was not met.
The right-wing government of Argentina, which has considered leaving the Paris Agreement, unveiled caps on the country’s emissions for 2030 and 2035 in an online event on November 3, but has yet to formalise those targets in an NDC.
Undersecretary of the Environment Fernando Brom told Climate Home News that the country would present its NDC during the first week of COP30. That did not happen, although Argentinian negotiators participated in the climate summit.
Some local experts have pointed to the trade deal signed with the US in November as one of the reasons for the delay in submitting the NDC, while others cited the government’s disinterest in the climate agenda.
In January, the Vietnamese government said it was still working on the draft of its NDC, while the Philippines’ government has organised consultation events on its new NDC but has not indicated when it would be released.
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Paris Agreement watchdog weighs action against countries missing climate plan
Climate Change
Australia’s climate credibility tested at Pacific Pre-COP talks, as High Court fossil fuel ruling puts government on notice
NADI, FIJI Thursday 8 October 2026 — As the Pacific Pre-COP talks wrap up and Australia prepares to take the reins of COP31 Negotiations in Türkiye next month, Greenpeace Australia Pacific says the government is on notice over fossil fuel expansion and exports, and must accelerate action to align with a 1.5°C pathway.
Following yesterday’s landmark High Court ruling that the climate impacts of coal and gas exports must be considered by New South Wales planning authorities, Greenpeace Australia Pacific is calling on the Albanese government to find the “courage, leadership and grit” to chart a new course away from fossil fuels.
High res images and video from yesterday’s ‘Keep 1.5C Alive’ flotilla in Nadi can be found here
Speaking from Nadi, Shiva Gounden, Head of Pacific at Greenpeace Australia Pacific, said:
“The outcomes of this week’s talks are a drop in the ocean given the scale of need, and urgency of the crisis our communities are facing. It is like taking a glass of water to a burning house if we do not urgently act to address the root cause of the existential threat facing Tuvalu, Fiji and all Pacific countries: fossil fuel expansion.
“The Electrification Pledge must end fossil fuel dependence, not be an end in itself — its ultimate success depends on ensuring electricity comes from renewable sources that displace fossil fuels and align with a 1.5°C pathway. It must be underpinned by justice and backed by finance flowing from polluters to communities.
“Limiting global warming to 1.5°C is a non-negotiable survival line for humanity and Australia must act. The landmark climate advisory ruling from the ICJ is clear — 1.5°C is the moral, the scientific and the legal limit. Continuing down the fossil fuel path, and failing to align efforts with limiting warming to 1.5°C, is a breach of our international legal obligations, and risks making Australia liable for future reparations from climate-vulnerable nations.”
Also in Nadi, Dr Simon Bradshaw, COP31 Lead and climate expert at Greenpeace Australia Pacific, said: “The Pacific was never going to be a mere backdrop for Australia in its role as incoming chair of the COP31 climate talks, but where its credibility and commitment to climate leadership would be tested.
“Here we see communities fighting for their survival and doing everything possible to hold the line on returning warming to 1.5°C. When governments profess to take their concerns seriously, only to then throw more fuel on the fire, the pain and sadness is visceral.
“This week the High Court of Australia recognised what the Federal Government refuses to — that Australia is responsible for the climate damage of our fossil fuel exports and if governments don’t act, the courts will intervene. The message is simple: this is not someone else’s problem, it is ours.
“We must now follow other countries in developing a national roadmap away from fossil fuels that ensures a managed wind-down of fossil fuel production, including exports, in line with our legal obligation to help return warming to 1.5°C.”
ENDS
Media contact: Kate O’Callaghan in Nadi on +61 406 231 892 (Whatsapp/Signal)
A Dutch NGO has filed the first climate complaint under the European Union’s trade rules, arguing that New Zealand violated the environmental provisions of its free trade agreement with the bloc by weakening its climate regulations.
The case will test whether binding climate provisions in the EU’s free trade deals can be enforced to hold governments accountable to their climate obligations, experts told Climate Home News.
The EU-New Zealand free trade agreement, which came into force in 2024, was the first in the world to include legally-binding climate provisions and possible sanctions for violating them, as the EU seeks to use its trade partnerships to advance greater environmental protection.
Under the deal, both parties committed not to weaken their environmental law to promote trade or investment and to “refrain from any action or omission that materially defeats the object and purpose of the Paris Agreement”.
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At the time the agreement was signed, EU Commission President Ursula von der Leyen said the agreement included “unprecedented social and climate commitments”. But experts warned it was unclear how the Paris Agreement provisions would be enforced.
The EU included a similar “trade and sustainable development” clause in 14 other bilateral trade deals in recent years, with several others, including with China, awaiting ratification or being negotiated.
Climate activists at the Dutch NGO Both ENDS argue that the New Zealand government breached these terms by reopening its waters to offshore oil and gas exploration, releasing a climate plan that barely requires any emissions reductions, and passing a law that prevents corporations from getting sued over climate damages.
“Here, we have a so-called gold standard for free trade agreements with sustainability provisions but we have a trading partner that is doing exactly the opposite: regressing, as all the evidence points to, away from the Paris Agreement,” said Marius Troost, a senior policy advisor at Both ENDS.
Can the EU enforce its climate trading rules?
The Dutch environmental group filed the complaint under the EU Commission’s Single Entry Point, a mechanism that allows civil society to request enforcement of the bloc’s trade commitments.
The EU-New Zealand trade deal includes the possibility of suspending beneficial trading arrangements between the two parties in response to serious violations of its climate provisions. This, Troost said, is a “unique” tool to enforce both parties’ obligations under the deal.
“This is an opportunity for the EU and New Zealand to show that they are actually serious about these commitments,” he told Climate Home News.
A spokesperson for New Zealand’s Ministry of Foreign Affairs and Trade denied any violations of the agreement and said the government hadn’t received formal notice of the complaint. The country, they said, “takes its commitments under the NZ-EU Free Trade Agreement seriously, including the agreement’s environment and climate-related provisions”.
An EU Commission spokesperson said it will start a preliminary assessment of the complaint and engage with NGO Both ENDS. “Sustainability is a central pillar of the EU-New Zealand relationship,” they added.
The EU is New Zealand’s second-largest trading partner after China, with about 14% of the country’s exports going to the European market. Agricultural products like meat, diary, fruit and vegetables are the country’s biggest exports to Europe.
New Zealand is ‘having its cake and eating it’
Eliza Prestidge-Oldfield, a senior legal researcher at the New Zealand-based Environmental Law Initiative, which is supporting Both ENDS’s claim, told Climate Home News that if the EU upholds the complaint, both parties would begin a negotiation process.
“The idea is to try and resolve this positively with the New Zealand government acknowledging areas where it needs to change its actions in order to comply with the agreement, and get that change in place as soon as possible,” she said.
But New Zealand’s right-wing coalition government said it won’t take any directives from foreign actors regarding its policies. Trade minister Todd McClay told local media that it was “not for overseas countries, organisations or lobby groups to tell New Zealand how to meet its obligations”.
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Prestidge-Oldfield argued the complaint isn’t about “Europe telling anyone what to do at all”, but rather stressing the conditions under which they are willing to import goods from New Zealand. “The New Zealand government is trying to have its cake and eat it too,” she said.
If New Zealand refuses to adjust its policies in line with the agreement, the complaint will be assessed by an independent panel, which can require the country to make changes. If those changes are not implemented, the panel could decide that New Zealand should lose its preferential EU market access.
A negotiated resolution is more likely, however, with no prior labour-related complaints to the EU having ever reached the panel stage.
Alexander Gillespie, a law professor at the University of Waikato in New Zealand, said sanctions would be a “last resort”. “This is a test case, which will generate considerable attention – as it is not just about climate change, but how free trade and environmental sustainability have been woven together,” he said in a statement.
Trade deals as tool for climate accountability
Experts said the case could set a precedent for how trade deals can be used to hold governments accountable on climate action. The EU has enacted similar “trade and sustainable development” clauses in its trade agreements with Canada, Japan and South Korea.
While still pending ratification, the EU’s 2024 trade agreement with Mercosur – which encompasses Argentina, Brazil, Paraguay and Uruguay – also includes climate provisions, including a commitment to “effectively implement” the Paris Agreement and promote low-carbon trade.
In addition, legal researcher Prestidge-O