Brussels, 18 March 2026
EREF welcomes the opportunity to provide input on the revision of the Governance
Regulation. The revision is the crucial foundation for the 2040 EU energy and climate
architecture. While framed as a governance and simplification exercise, it will in
practice determine whether the EU’s 2040 climate objective translates into a credible
delivery framework and stable, predictable investment signals.
The Commission’s own assessment reinforces this urgency. Even assuming full
implementation of current plans, a 1.5 percentage point gap remains towards the
binding 42.5% renewable energy target for 2030 (with a further 2.5 percentage points
needed to reach the 45% indicative aspiration) — and only if existing plans are actually
delivered in full. Annual investments of around €695 billion will be required between
2031 and 2040 to stay on track.1
Any simplification should strengthen implementation, transparency and enforceability.
It must not dilute accountability or weaken the investment certainty required to deploy
very high renewable energy shares and achieve Europe’s energy transition.
This is particularly important in a context where pressure is growing to reframe the
post-2030 architecture under broad “clean” or “low-carbon” banners. Where renewables
are no longer clearly distinguished as the primary delivery option, the credibility of
fossil phase-out, system integration and timely delivery is undermined. This would also
delay the necessary strengthening of supply security, slowing Europe’s efforts to
reduce import dependence and improve competitiveness.
A credible post-2030 architecture needs a clear renewable energy anchor
The climate target alone does not provide investment certainty or system guidance. It
must be operationalised through renewable energy targets and governance that are
clear, measurable and enforceable.
To reach Europe’s 2040 climate goal of 90% GHG reduction, EREF underlines that
a dedicated renewable energy target remains indispensable as the central energy
anchor. The governance framework should preserve a binding renewables target
expressed as a share of gross final energy consumption — the only metric providing
cross-sector clarity across electricity, heating and cooling, transport and industry alike.
This ensures coverage of the full range of renewable technologies — including wind,
solar, hydropower, bioenergy, geothermal and ocean energy — each contributing to
delivering high renewable shares across all sectors and end-uses.
Energy efficiency must remain a core pillar of this architecture. It reduces overall
system pressure, limits grid reinforcement needs and supports lower energy bills. The
Governance Regulation should therefore reinforce efficiency in planning and delivery,
alongside the renewables anchor.
Electrification is an important enabler but cannot replace a renewables target.
Electrification on its own does not guarantee GHG reduction or defossilisation, since it
can be achieved with fossil-based or nuclear electricity. It should be embedded under
a renewables-based trajectory and complemented by energy efficiency, grid investment,
storage and non-fossil flexibility.
Governance as delivery, not deregulation
Implementation gaps under the existing 2030 framework remain significant. Almost all
Member States have been subject to infringement procedures related to incomplete or
delayed transposition of the Renewable Energy Directive.2Europe’s competitiveness
challenge lies in weak implementation, slow roll-out of enabling infrastructure and
insufficient accountability; not in excessive EU-level ambition.
Given the lack of binding national targets, NECPs are currently the Commission’s most
effective coordination and enforcement tool. The revised Regulation should strengthen
NECPs as delivery and investment instruments, including by requiring Member States
to:
● prioritise the timely delivery of renewable energy projects and enabling
infrastructure, including grids, storage, flexibility solutions and heat networks;
● identify implementation bottlenecks and set out concrete measures,
responsible authorities and timelines to address them;
● provide more credible investment planning, including clearer identification of
investment needs and pathways to mobilise private capital;
● ensure coherence between NECPs and core planning and implementation
frameworks, notably TYNDPs, EU infrastructure planning, the European
Semester and relevant EU funding instruments, to reduce fragmentation and
increase deliverability.
Where longer time horizons up to 2050 are considered, they should improve long-term
investor visibility whilst preserving interim accountability, interim targets and the
established NECP rhythm.
It is equally important that the internal energy market functions in a way that ensures
fair market access and cost-reflective pricing for all stakeholders. An increasing range
of policy-related charges is being added to electricity prices that would historically
have been financed through general budgets. This disproportionate loading of costs
onto energy bills distorts price signals, undermines consumer acceptance of the
transition and weakens incentives for electrification and demand-side participation.
A credible governance framework should therefore safeguard fair cost allocation,
transparent pricing and non-discriminatory access across the Union.
Accountability and enforcement must close the delivery gap
To ensure collective achievement of EU objectives, the revised Governance Regulation
should strengthen compliance through clearer obligations, improved monitoring and
a stronger Commission toolbox. Simplification should focus on practical measures such
as clearer templates, digitised reporting and data reuse, whilst preserving strong
oversight and enforcement. Simplification must not become reduced scrutiny.
EREF particularly underlines the need for:
● stronger reporting obligations and improved data quality, precision and
comparability across Member States;
● earlier and more effective Commission review of both ambition and
implementation, enabling intervention where progress is insufficient;
● a reinforced corrective-action framework building on existing gap-filling
mechanisms, with faster follow-up and clearer consequences;
● credible enforcement pathways, including infringement and penalty
mechanisms where necessary, to ensure compliance and provide investment
certainty;
● stronger transparency and tracking of the phase-out of fossil fuels and fossil
fuel subsidies, as a core condition for a level playing field and a credible
transition.
Investment certainty depends on credible national planning
A stable and predictable investment environment after 2030 depends primarily on the
clarity, credibility and enforceability of national planning. The scale of capital
mobilisation required — around €695 billion annually between 2031 and 2040 —
cannotbe achieved without governance frameworks that provide genuine long-term
bankability for renewable energy investments.
The Governance Regulation should therefore strengthen NECPs as
investment-enabling roadmaps through more granular and comparable information on
investment needs, infrastructure requirements and financing pathways; concrete
measures to engage investors and financial institutions; clearer and digitised
templates enabling comparability across Member States; and stronger coherence
between NECPs and EU-level planning and funding instruments, including TYNDPs, the
European Semester and the next MFF.
KPIs can effectively support delivery monitoring where they are clearly linked to
implementation bottlenecks and system enablers. However, they must remain
complementary and must not replace binding targets and enforceable obligations.
Avoiding dilution through “clean energy” or “low-carbon” reframing
EREF cautions strongly against approaches that replace renewables-specific targets
with vague “clean energy” or “low-carbon” framing. Such an architecture would dilute
renewables-specific investment signals and increase uncertainty for renewable project
developers, including independent producers, SMEs and energy communities.
A “clean energy” framing also risks channelling political and financial focus towards
slower-to-deliver, capital-intensive options, weakening delivery discipline for 2040.
Renewables must be clearly distinguished from broader categories. Complementary
metrics can be useful only where they reinforce — and do not blur —
a renewables-based trajectory and credible fossil phase-out.
System enablers: grids, storage and non-fossil flexibility
Planning and reporting should more explicitly integrate grid readiness, storage and
demand-side flexibility into national delivery pathways, so that renewable deployment
is feasible in practice and not delayed by avoidable system bottlenecks. Strengthening
the link to internal market rules and non-fossil flexibility resources supports security of
supply and resilience, and makes a high-renewables system deliverable at scale.
The full range of renewable technologies — wind, solar, hydropower, bioenergy,
geothermal and ocean energy — must be recognised as integral to this system. Their
complementarity and, in the case of hydropower and bioenergy, dispatchability, create
synergies essential to system flexibility and security of supply.
Conclusion
The revision of the Governance Regulation should translate the EU’s post-2030
objectives into a clear and enforceable delivery framework, with renewable energy at
its core. This requires maintaining a binding renewable energy share target, keeping
energy efficiency as a core pillar, and treating electrification and other indicators as
supporting enablers within a renewables-based trajectory.
A stronger focus on implementation, accountability and enforcement is the most
cost-effective way to deliver Europe’s energy transition, strengthen competitiveness
and ensure energy security. A governance framework that is stable, transparent and
enforceable reduces investment risk, crowds in private capital and accelerates delivery
— making Europe’s 2040 ambition both credible and bankable.
For more information, please contact
Prof. Dr. Dörte Fouquet
Director
doerte.fouquet@eref-europe.org
Dirk Hendricks
Secretary General
dirk.hendricks@eref-europe.org