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.

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

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