Social Climate Plans need to pave the way for ending energy poverty
Written by Eva Brardinelli, Senior Buildings Policy Expert at CAN Europe and Eva Schwab, Policy Officer at FEANTSA.
The Social Climate Plans are more than a mere “paper exercise”, they are foundational tools to shield the most vulnerable.
Today marks a significant milestone in the European Union’s pursuit of a just and inclusive green transition. Member States are officially required to submit their National Social Climate Plans (SCPs), a pivotal step in ensuring social justice in the implementation for the upcoming EU Emissions Trading System 2 (EU-ETS 2), which will expand carbon pricing to road transport and buildings.
The Social Climate Plans are more than a mere “paper exercise”, they are foundational tools to shield the most vulnerable from the costs of fuels, which are expected to rise under this new system, which is set to start as soon as 2027. Above all, these Plans are one step in addressing one of Europe’s most persistent challenges: energy (and transport) poverty.
Energy poverty is not a one-size-fits-all problem. It affects different people in different ways, often hidden behind data gaps, inconsistent definition and general assumptions. To truly make a dent in energy poverty, Member States must begin by better understanding who is most affected, how, and why. Data shows that relying on national statistics alone is not enough, in fact up to one-third of essential data on household energy vulnerability is incomplete, outdated, or inconsistently collected, potentially hindering effective targeting in Social Climate Plans.
This makes local knowledge and direct community engagement paramount. Reaching the right people requires breaking from the silos of intricate spreadsheets. It means going out into communities, collaborating with local actors, and listening to lived experiences. It also means acknowledging the complexity of vulnerability, where factors such as low income, debt, poor and insecure housing, rural isolation, or disability and chronic illness (among others) can intersect and compound energy hardship. Local authorities, civil society organisations (CSOs), especially those representing vulnerable people and communities have the most local and pertinent data, and they also have the acquaintance with and trust of those communities. Their early and sustained involvement in the drafting and implementation of SCPs is essential.
Quality and long-term participation is the only way to avoid “piece-meal” approaches where a quick and “unbureaucratic” rollout of the plan and spending of the money is favoured at the expense of measures and investments that are actually useful, targeted, and accepted by those they’re meant to support. For example, a subsidy for home insulation might be technically and economically sound but ineffective if it requires upfront costs that the most vulnerable households cannot cover. CSOs and local actors can flag these pitfalls early, only if they’re involved from the beginning.
Inclusive, meaningful public participation can build up trust and ownership of these Plans, which can create the essential buy-in to enable their successful implementation. But public authorities must also be held accountable for the effectiveness of the measures and investments by installing mechanisms receptive to the feedback by CSOs on whether or not these measures are actually helping households in energy poverty.
Within the broader fight against energy poverty, the submission of SCPs is an important deadline, but not the final destination. The Social Climate Fund alone will not be enough to tackle energy poverty. Renovation needs of low-income households in the CEE region alone amount to EUR 140 billion while the Social Climate Fund is only EUR 86.5 bln. However, this should not discourage policy makers from designing ambitious plans. These Plans should be seen as the first step in a long-term strategy to ensure no one is left behind in the green transition in the built environment.
Because of their objectives, NSCPs should interlink with and complement other national strategies, among which the National Building Renovation Plans (NBRPs) and National Energy and Climate Plans (NECPs). Aligning the policies and measures stemming from these Plans can prevent fragmentation and ensure that support reaches vulnerable households through multiple, coordinated channels and financial streams.
The SCPs are also an important vehicle to meet the new criteria for the usage of ETS2 revenues and, indeed, Member States are encouraged to add funding to their SCPs from the national revenues. Since the ETS recast, 100% of ETS2 revenues have to be used for climate-related purposes with a priority to measures that mitigate the social impact of those policies.
Today’s deadline for SCPs will be missed by many countries. We need targeted stakeholder consultations and ideally the installation of inclusive monitoring bodies to track effectiveness and implementation of these Plans. But time must be used wisely. The ETS2 will likely increase energy prices, while structural measures that lift households out of energy poverty need time to gain traction. Therefore with well-designed Social Climate Plans, that are rooted in participation and inclusive governance, and aligned with broader strategies and funds (most importantly the National Building Renovation Plans and additional ETS2 revenues), which are complemented with socially targeted use of relevant EU and national funds, we have a chance to break the trail towards a more just, inclusive, and sustainable Europe.
