Facing the Opportunities and Challenges of the Features of NDCs Discussion Paper

1. In 2015, 195 countries confronted climate change and the collective action problem it presents by doing something no prior climate accord had achieved. The Paris Agreement secured near-universal agreement for countries to act, without requiring universal agreement as to how. This was made possible by the Nationally Determined Contribution (NDC), which asks each Party to define its own commitment, taking into account its capacities and circumstances within a shared framework of transparency and review. The result was a coordinated architecture of distinct national commitments, bound together by a shared expectation of ambition over time.
2. The context for these discussions has changed significantly since negotiations on NDC features first began. Before the adoption of the Paris Agreement, Parties were invited to communicate their “intended nationally determined contributions” (INDCs) well in advance of COP21—and by the first quarter of 2015 if ready to do so. Many of these INDCs became Parties’ first formal NDCs. The second round of NDCs was due in 2020. The third round of NDCs (NDCs 3.0)—with an end date of 2035—was due by February 10, 2025.²UNFCCC, Report on the 11th meeting of the Paris Agreement Implementation and Compliance Meeting, PAICC/2024/M11/4, ¶ 19, (April 17-19, 2024), https://unfccc.int/sites/default/files/resource/PAICC_11_meeting_report.pdf.
3. Over three successive cycles, Parties have noted they have greater experience with the formulation and implementation of their NDCs. The 2025 NDC Synthesis Report—informed by the 64 Parties that submitted their NDCs 3.0 by September 30, 2025—notes that “new NDCs show a progression in terms of quality, credibility and economic coverage.”³UNFCCC, Nationally determined contributions under the Paris Agreement synthesis report by the Secretariat, CMA.7, (October 25, 2025), https://unfccc.int/documents/650664. An updated NDC synthesis report is expected to be published ahead of COP31.
4. The climate science is also clearer. The Intergovernmental Panel on Climate Change (IPCC) published the final pieces of the sixth assessment report (AR6) in March 2023, which acknowledges that “widespread and rapid changes in the atmosphere, ocean, cryosphere and biosphere have occurred” leading to widespread impacts to nature and people.⁴Intergovernmental Panel on Climate Change, Summary for Policymakers. In: Climate Change 2023: Synthesis Report. (Geneva, Switzerland: IPCC, March 2023), https://www.ipcc.ch/report/ar6/syr/downloads/report/IPCC_AR6_SYR_SPM.pdf.
5. The broader Paris Agreement architecture has matured as well. The conclusion of the Paris Agreement’s first GST at COP28 set out further guidance, key signals, and collective targets that should inform Parties’ NDCs and Parties’ first BTRs contain information on tracking NDC progress.
6. These developments may provide reasons for Parties to revisit the discussion of NDC features with an eye to how NDCs have evolved over these three cycles, and how NDCs may change further given these experiences.

Background: Prior NDC Features Discussions

7. While there is no agreed definition of the word “features” in the context of NDCs, it is widely understood to refer to the characteristics of NDCs.

8. Paragraph 26 of Decision 1/CP.21 requested that the Ad Hoc Working Group on the Paris Agreement (APA) develop further guidance on features of NDCs for consideration and adoption during the first session of the Conference of the Parties serving as the meeting of the Parties to the Paris Agreement (CMA1).⁵UNFCCC, Adoption of the Paris Agreement, Decision 1/CP.21, ¶ 26, (January 29, 2016), https://unfccc.int/resource/docs/2015/cop21/eng/10a01.pdf. Despite several rounds of negotiations under the APA, Parties were unable to reach agreement on further guidance.

9. It was subsequently decided that the CMA would “…continue consideration of further guidance on features of [NDCs] at its seventh session (2024).”⁶UNFCCC, Further guidance in relation to the mitigation section of decision 1/CP.21, Decision 4/CMA.1, ¶ 20, (December 17, 2020), https://unfccc.int/sites/default/files/resource/4-CMA.1_English.pdf. Because there was no COP in 2020 due to the COVID pandemic, Parties agreed to consider further guidance at CMA6 in 2024.

10. At CMA6 in Baku, Parties engaged in discussion on “Further guidance on features of nationally determined contributions, referred to in paragraph 26 of decision 1/CP.21”. Parties expressed views with in-session submissions,⁷UNFCCC, Compilation of submissions by Parties: Further guidance on features of nationally determined contributions, referred to in paragraph 26 of decision 1/CP.21, Decision 1/CP.21, (November 18, 2024), https://unfccc.int/documents/644017. but once again were unable to find consensus on features of NDCs and “agreed to continue consideration of this matter” at CMA8 in 2026.⁸UNFCCC, CMA 6 agenda item 7, status, https://unfccc.int/event/cma-6.

11. As Parties approach renewed discussions on NDC features at CMA8 in Antalya, perhaps they could benefit from a fresh perspective. Rather than repeating prior positions, there may be an opportunity to have a simple conversation about how NDCs have changed. Parties could reflect on how NDCs have evolved, particularly in their form and substance. What might this type of discussion surface about the nature of NDCs and their collective utility?

What’s Changed: Developments Relevant to NDC Guidance

12. Since the first negotiations on NDC features in 2016, the Paris Agreement has entered full effect, and the broader climate landscape has evolved considerably, giving rise to developments that could inform NDCs, including:

• Scientific developments: the IPCC has elevated new scientific findings in the AR6.
• Temperature goals: greater emphasis has been placed on achieving net zero emissions by 2050 and on adaptation amid efforts to limit warming to 1.5 degrees C.
• Global stocktake: the first global stocktake (GST1) concluded at COP28 in 2023, informing the third round of NDCs. The second GST will commence at COP31.
• NDC experience: 2025 marked the third round of NDC development and implementation, including the provision of the information to facilitate clarity, transparency and understanding (ICTU) of NDCs.
• Biennial transparency reports: most Parties have submitted their first biennial transparency reports (BTRs), which include provisions for tracking NDC progress. Many are now preparing their second BTRs, which face a deadline of December 31, 2026.

Emerging Trends: The Evolution of NDCs

13.Parties are reflecting the developments in the UN climate regime and the broader landscape in their NDCs. The UNDP Climate Promise Insight Series identifies several trends across the 128 NDCs 3.0, representing about 78 percent of GHG emissions, submitted by Parties as of 31 December 2025:⁹UNDP, A Decade of the Paris Agreement: A Compendium of NDC Insights, Final Issue.

• Mitigation: Parties are increasing the number of sectors covered in NDCs, with 89 percent expanding sectoral mitigation measures. More than 75 percent of NDCs surveyed by Climate Promise include economy-wide emissions reductions targets, some for the first time.¹⁰UNDP, A Decade of the Paris Agreement: A Compendium of NDC Insights, Final Issue, 11.
• Adaptation: NDCs are increasingly aligned with National Adaptation Plans (NAPs). More than 80 percent of the new NDCs included in the UNDP study reference NAPs, and 78 percent of these expanded to include adaptation in new sectors.¹¹UNDP, A Decade of the Paris Agreement: A Compendium of NDC Insights, Final Issue, 13.
• GST alignment: 95 percent of NDCs surveyed include at least one policy commitment towards reaching the GST energy goals of tripling renewable energy capacity, doubling energy efficiency gains, or transitioning away from fossil fuels.¹²UNDP, A Decade of the Paris Agreement: A Compendium of NDC Insights, Final Issue, 16.
• LT-LEDS alignment: new NDCs surveyed are largely consistent with their 2030 targets and long-term net-zero targets. However, NDCs face persistent gaps in short- and medium-term ambition, pointing to the need for greater immediate implementation of mitigation measures.¹³UNDP, A Decade of the Paris Agreement: A Compendium of NDC Insights, Final Issue, 12.
• Just Transition: 94 percent of NDCs surveyed introduce measures to achieve just transition.¹⁴UNDP, A Decade of the Paris Agreement: A Compendium of NDC Insights, Final Issue, 56.
• Carbon markets: 71 percent of the NDCs included in the UNDP study reference Party plans to use carbon market mechanisms under Article 6.¹⁵UNDP, A Decade of the Paris Agreement: A Compendium of NDC Insights, Final Issue, 62.
• Transparency: Parties are increasingly institutionalizing reporting provisions. 88 percent of NDCs by developing country Parties establish permanent national transparency systems.¹⁶UNDP, A Decade of the Paris Agreement: A Compendium of NDC Insights, Final Issue, 59.
• SDGs alignment: certain SDGs are well reflected across new NDCs. 99 percent of the NDCs surveyed include measures to address SDG 7 (energy); 87 percent do the same for SDG 11 (cities and communities); 75 percent do so for SDG 15 (forests and land-based ecosystems).¹⁷UNDP, A Decade of the Paris Agreement: A Compendium of NDC Insights, Final Issue, 53.
• Investability: NDCs increasingly include stronger signals for investment. 80 percent of new NDCs assessed in the study incorporate signaling elements for expected outcomes such as quantified targets, sectoral priorities, high-level cost estimates, and policy frameworks.¹⁸UNDP, A Decade of the Paris Agreement: A Compendium of NDC Insights, Final Issue, 62.

14. The 2026 NDC Synthesis Report, due in October 2026, is expected to further highlight how NDCs 3.0 have evolved and what trends have emerged.

Adding Value: Benefits of Further NDC Guidance

15. As trends emerge across NDCs, further guidance on NDC features from Parties could strengthen the utility of these instruments and deliver diverse benefits, including:

• Measures of collective progress: A consistent methodology for target-setting could reduce the technical burden associated with developing quantitative and qualitative goals and enable better data aggregation. The result may be a more comprehensive measure of collective progress that benefits from efficiency gains and informs the next GST.¹⁹Sirini Jeudy-Hugo et al., Insights for designing mitigation elements in the next round of National Determined Commitments, 38, 39, the OECD/the International Energy Agency Climate Change Expert Group Papers, (Paris, France: OECD Publishing, 2024), https://doi.org/10.1787/b70a88ef-en.
• Aligned domestic policies and long-term strategies: NDCs frame domestic policy development and can serve as an entry point for domestic climate action. Parties could consider guidance on features such as economy-wide targets, peaking years, absolute emissions reduction targets against a baseline, and alignment with 1.5ºC and LT-LEDS to inform policymaking. This could enable Parties to streamline future climate planning; enhance domestic implementation; and align domestic development and economic policies with climate priorities.
• Investment in NDC implementation: NDC features guidance could provide information that improves investors’ understanding of domestic policy landscapes, risks and opportunities. Investors have noted that more granular detail on sectoral pathways and quantified investment needs have been helpful in advising their decision-making processes.²⁰Institutional Investors Group on Climate Change, “Making NDCs investable – the investor perspective,” (London, UK, June 2024), https://www.iigcc.org/hubfs/POLICY/IIGCC_Making%20NDCs%20investable%20-%20the%20investor%20perspective_June2024.pdf.
• Synergies across relevant negotiation processes: In addition to upcoming NDC features negotiations, Parties are expected to review guidance for the ICTU of NDCs in 2027.²¹UNFCCC, Matters Relating to the implementation of the Paris Agreement, Decision 3/CMA.1, ¶ 18, (March 19, 2019), https://unfccc.int/documents/193407; OECD, Insights for designing mitigation elements in the next round of National Determined Commitments, 38. Identifying how best to reflect growing trends across NDCs in negotiated outcomes may improve coherence and coordination ahead of the next NDC cycle.

The Case for Caution: Challenges to Further NDC Guidance

16. Developing further guidance on features of NDCs faces several challenges, including:

• Defining “features” of NDCs: To date, no CMA decision has officially defined “features” as it relates to NDCs. Although it is generally understood that “features” refers to components or characteristics of NDCs, when negotiations resume, Parties could establish a common definition of NDC features that maintains their nationally determined nature.²²Ad-hoc Working Group on the Paris Agreement, Informal Note to Co-facilitators, (November 14, 2016), https://unfccc.int/sites/default/files/informal_note_item3_v2.pdf.
• Clarifying the relationship between guidance on NDC features and guidance on the ICTU of NDCs: The upcoming review of ICTU guidance could raise overlapping issues. Parties could consider ways to avoid duplicative processes that reduce technical capacity.²³OECD, Insights for designing mitigation elements in the next round of Nationally Determined Contributions, 38.
• Determining scope of refinement: NDCs reflect the fact that Parties have increasingly diverse experiences with climate change. Parties could consider what elements, if any, could usefully be included in guidance for NDC features, recognizing the tension between the collective nature of guidance and that not all features will be applicable to all Parties.²⁴OECD, Insights for designing mitigation elements in the next round of Nationally Determined Contributions, 39.
• Limited time to discuss “features” further: Parties will face competing priorities for negotiating time at CMA8 and are unlikely to have many opportunities to discuss features. In the limited time available before CMA8, Parties could try to informally exchange ideas where possible. At CMA8, Parties could focus discussions on national experiences of NDC evolution, and how to enhance NDCs as a tool without infringing on their nationally-determined nature.

17. Exploring these developments could help Parties better understand the role of NDC features and whether shared lessons could support future NDC design, while preserving Party ownership.

Moving Forward: How Parties Could Consider Approaching Negotiations

18. As Parties prepare to negotiate further guidance on features at CMA8, they might consider:

• Taking stock of NDCs’ evolution: The upcoming 2026 NDC Synthesis Report prepared by the UNFCCC Secretariat and the Climate Promise Insight Series from UNDP provide valuable insight into NDC development. A presentation or briefing by these bodies and other relevant organizations could ensure all Parties have access to the latest expert findings to inform negotiations following the third cycle of NDC submissions.
• Identifying an agreed purpose and boundaries: Following periodic negotiations on NDC features, Parties could seek to build trust by identifying an agreed direction of discussion. Beginning with an understanding of why NDCs may benefit from guidance if trends are independently emerging (i.e., to recognize progress, stabilize progress, improve capacity, and provide domestic guidance on climate action) could build on the UNFCCC Secretariat’s and UNDP’s findings and lay the groundwork for a productive discussion.
• Pursuing “light touch” guidance: Talk about prescriptive guidance is unlikely to yield fruitful negotiation. Instead, Parties could consider a “light touch” approach to features guidance that recognizes the diversity of Party experiences with climate change while reflecting lessons learned in NDC development. The Quality Assurance Checklist for NDCs published by UNDP could serve as a shared framework for features development that is rooted in UNDP’s analysis.²⁵OECD, Quality Assurance Checklist for Nationally Determined Contributions (NDCs) 3.0, (New York City, NY: UNDP, February 2025), https://www.undp.org/publications/quality-assurance-checklist-nationally-determined-contributions-ndcs-30. The latest edition could even be referenced in the CMA8 outcome on features.
• Addressing upcoming timelines: Parties may choose to prepare for future discussions on features guidance following COP31. They might also consider how the upcoming review of ICTU guidance in 2027 and NDC features negotiations could be mutually reinforcing. ICTU development could be considered an example of a NDC feature that has benefited Parties and NDC development. Parties could also consider how the design of the post-2030 sustainable development agenda and UN80 Initiative will influence future NDCs.