At least fifty countries have yet to submit a nationally determined contribution (NDC) climate plan to the United Nations, even though the latest set of plans was due in 2025 – and among them, around half have failed to provide information on why they have not met the deadline.

More than a year past an initial deadline of February 2025, the Paris Agreement’s Implementation and Compliance Committee (PAICC) met this March and said 55 countries had yet to communicate an NDC to the UN climate body. According to the UN’s registry, two have since submitted their plans.

A key requirement of the landmark 2015 Paris Agreement is that governments publish a more ambitious NDC every five years, setting targets to reduce their planet-heating emissions and outlining their policies to adapt to climate change, in order to meet the accord’s goals on limiting global warming and protecting people from its effects.

The latest set – the third round of plans, with new targets for 2035 – was due in 2025.

After India’s recent submission, the countries yet to publish their new NDCs are mostly poorer and smaller nations, with few emissions. The biggest emitters in the group are Egypt, Vietnam, Argentina and the Philippines. The US and Iran are not signed up to the Paris Agreement, although the US submitted a 2035 NDC under the Biden administration before Donald Trump pulled the US out of the UN climate accords.

Some nations have argued that they cannot put together an NDC – which requires a significant amount of work in tracking emissions and consulting on how to curb them across the economy – because of exceptional circumstances. For example, a letter from a Sudanese official to the PAICC committee, seen by Climate Home News, says that the country’s civil war has led to the suspension of its NDC preparation.

No information from some nations

But others have failed to communicate with the PAICC, which is tasked with encouraging governments to respect their commitments under the Paris Agreement.

In a report on its March 27 meeting, the PAICC board said it “noted with concern” that 28 countries have not provided information about either their NDCs or their biennial transparency reports on the climate action they are taking, or both. This was “despite several reminders”, it said.

Despite a push from some board members, the committee did not agree at this meeting to name these 28 countries. But it may do so at a meeting in September.

One source who has seen the list of countries told Climate Home News it was a “mixed crowd” of developing nations, including least developed countries, small island developing states, emerging economies and at least one government with a representative on the PAICC board.

The PAICC decided to send individual letters to these governments requesting that they engage with the committee and “reminding them that it shall take appropriate measures with a view to facilitating implementation and promoting compliance” with the Paris Agreement.

Non-punitive system

The PAICC’s rules of procedure state that it should be “non-adversarial and non-punitive” and the strongest measure it can take is to issue a public finding naming a government that has breached the Paris Agreement rules. It has done this once before in 2023, rebuking the Vatican for not filing an NDC and Iceland for not telling the UN how much climate finance it plans to provide.

Joanna Depledge, a historian of the UN climate process and research fellow at the University of Cambridge, said that “any measures stronger than naming and shaming would have been unacceptable” to some governments when they were negotiating the Paris Agreement.

She added that “naming and shaming in the international arena is not trivial” because governments do not like to be exposed as non-compliant. “But if the PAICC cannot even name, then that is a serious problem,” she warned.

Avoiding Kyoto’s mistakes?

Tejas Rao, who is researching the PAICC as part of a doctoral thesis at Cambridge, said the architects of the Paris Agreement made it less enforceable so as to try and prevent countries leaving or staying out of the agreement as happened with its predecessor, the Kyoto Protocol.

While the Paris Agreement asks all governments to set their own emissions-reduction targets, the 1997 Kyoto Protocol set specific targets for developed countries.

When in 2011 it became clear that Canada was not going to meet those targets, it quit the agreement rather than face formal non-compliance proceedings and a multibillion-dollar obligation to buy carbon credits to cover the shortfall, Rao said.

Japan and Russia also declined to endorse some of their emissions reduction targets and the US never ratified the Kyoto agreement. “Enforcement proceedings became politically toxic,” exposing “the limits of punitive compliance regimes”, Rao said.

The idea of the Paris Agreement’s less stringent compliance system is to engage with governments and keep them within the system rather than threaten them with sanctions and potentially push them out, he added.

Rao said this was “the right trade-off” because governments comply when they feel they have chosen to sign up to the rules rather than having them imposed. He noted that back in April 2025, 171 governments had yet to submit their NDCs and this figure is now down to just over 50.

“We’ve got countries that are at least reporting NDCs,” he said, adding that PAICC is “working as it was designed to”. “It is issuing findings of fact and non-compliance, it’s initiating discussions with parties and, as a result of those discussions, the non-compliance figures are coming down every time.”

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