Authors:
- Rimma Kushtym, Component Manager, IKI Interface Ukraine Project, GIZ
- Daniela Göhler, Project Director, Implemention of Paris Agreement in Ukraine, GIZ
Introduction:
Despite the full-scale war, Ukraine continues to advance its climate policy and fulfill its international obligations. In 2025, the country took two major steps by adopting its Second Nationally Determined Contribution (NDC2) and submitting its first Biennial Transparency Report (BTR) to the UN Framework Convention on Climate Change (UNFCCC). These two documents are interlinked through a single strategic framework. The NDC2 defines Ukraine’s climate ambition and modernisation goals through 2035, while the BTR provides the mechanism for internationally verified progress tracking.
Together, they form a “currency of trust” — enabling Ukraine not merely to declare intentions, but to substantiate them with credible data for international partners and investors. Presented at the 30th UNFCCC Conference of the Parties (COP30) in Brazil, this framework demonstrates that Ukraine, even under wartime conditions, plans its recovery in line with European standards.
Why do climate issues remain a priority when Ukraine is fighting for its survival, and how can climate commitments unlock recovery financing? This article explores these questions.
Climate Policy as a Foundation for Recovery and EU Integration
Ukraine’s post-war recovery is not about restoring the past. It is about rebuilding a more resilient and competitive economy, modernizing and decentralizing the energy system and accelerating EU integration. The NDC2 plays a central role in this transformation.
The document sets a target to reduce greenhouse gas emissions by more than 65% by 2035 compared to 1990 levels. Its development is unique: the modelling was conducted under wartime uncertainty and based on the Fourth Rapid Damage and Needs Assessment (RDNA4), which estimates direct war damages at USD 176 billion and recovery needs at USD 524 billion. As a result, the NDC2 functions not only as a climate commitment but also as an investment roadmap for transforming Ukraine’s energy, industry, and transport sectors.
The process was supported by the IKI Interface Ukraine project implemented by Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ), ensuring alignment with EU climate policy. The scientific approach compares two scenarios: “With Existing Measures” (WEM) and “With Additional Measures” (WAM). The latter, selected as the target scenario, prioritizes deep energy modernisation and decarbonisation, helping to prevent an emissions rebound during reconstruction.
The NDC2 also strengthens climate change adaptation. For Ukraine, whose energy and industrial infrastructure have been deliberately targeted, adaptation is a matter of national security. Resilient technologies and climate-proofing of critical infrastructure need to be integral to recovery planning.
A key principle is a just transition, enshrined in Ukraine’s climate law, which links decarbonisation with job creation and social support for coal-dependent regions. NDC2 is aligned with the National Energy and Climate Plan and serves as a benchmark for access to EU funding, including the Ukraine Facility. Importantly, it remains flexible and can be revised as security conditions improve.
Building Trust Through Climate Transparency
As climate diplomat Peter Betts noted (Climate Diplomacy):
“Transparency is at the heart of an effective international regime… The details of transparency can be overwhelmingly technical and often very dull — but if you do not get transparency right and ensure it is implemented, commitments may have little value.”
Ukraine’s first BTR demonstrates this in practice. Despite wartime data losses, Ukraine submitted its BTR in line with global standards, underscoring the resilience of its national Monitoring, Reporting and Verification (MRV) system. The report was prepared through close cooperation between the Ministry of Economy, Environment and Agriculture and scientific institutions, including the Institute for Economics and Forecasting of the National Academy of Sciences of Ukraine, ensuring methodological rigor and compliance with UNFCCC requirements.
The BTR is significant in three ways. First, it provides a robust evidence base. In 2023, Ukraine’s greenhouse gas emissions were 75.8% lower than in 1990, with the steepest declines in energy (-77.8%) and industry (-82.1%). However, these reductions resulted from “non-natural” causes — namely, the destruction of facilities, damage to energy infrastructure, and occupation of territories — reflecting the scale of losses rather than climate success.
Second, the submission of the BTR triggers an international technical expert review under Article 13 of the Paris Agreement, strengthening confidence in Ukraine’s data and the transparent use of climate finance.
Third, the BTR has diplomatic and legal importance. While Russia manipulates climate reporting by including data from temporarily occupied territories, Ukraine reports strictly within its internationally recognised 1991 borders, reinforcing Ukraine’s territorial integrity within UN processes and preventing the misuse of climate mechanisms to legitimise occupation.
Data collection for the next BTR (2026) has already begun, enabling continuous monitoring and timely policy adjustments during recovery.
From Planning to Action: Building the Recovery Architecture
Together, the NDC2 and BTR form the backbone of Ukraine’s recovery architecture. They unlock access to international and market-based climate finance, support investments in energy efficiency and renewables, and create tangible benefits for businesses and households, such as warmer homes and lower energy bills.
Another important outcome is Ukraine’s preparation for the European rules of the game. Data collected through the BTR form the basis for a national emissions trading system compatible with the EU framework. This system introduces incentives that make it economically beneficial for businesses to reduce pollution: those who cut emissions pay less.
The BTR is also critically important for Ukrainian exporters, as it helps reduce risks associated with the introduction of the EU Carbon Border Adjustment Mechanism (CBAM). The clearer the understanding of a product’s emissions — its carbon footprint — the easier and more cost-effective it becomes to access the European market.
Ultimately, climate planning and transparency are not abstract exercises. For Ukraine, they are practical tools for rebuilding the economy, creating jobs, securing recovery funding, protecting national business, and advancing EU integration. In this sense, climate policy is not a secondary concern—it is a cornerstone of Ukraine’s resilient, European future.
Source: https://rubryka.com/en/blog/yak-ukrayina-formuye-svoye-zelene-vidnovlennya/
Acknowledgement: Oleksandr Diachuk, PhD, Senior Researcher at the Institute for Economics and Forecasting of the National Academy of Sciences of Ukraine, has contributed to this article.
The article was prepared in the context of the projects “IKI Interface: Supporting Ukraine towards Ambitious and Integrated Climate Policy (GreenUkraine)” and “Supporting Ukraine in the implementation of the Paris Agreement and adaptation to the impact of climate change in the Black Sea region (PAABS),” implemented by Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH on behalf of the Federal Ministry for the Environment, Climate Action, Nature Conservation and Nuclear Safety (BMUKN) under the International Climate Initiative (IKI).
