Berlin, May 15, 2025 – Today, the Council of Experts on Climate Change published its review report of the German greenhouse gas emissions for the Year 2024 and the projection data of 2025.

Expert Council finds no budget overshoot by 2030 despite underestimated emissions in projection data

The Expert Council verified the emissions data calculations for the year 2024 and has confirmed the results presented by the Federal Environment Agency. The report indicates that both the buildings sector and the transport sector once again exceeded their annual emission budgets in 2024. In both sectors, the exceedance was higher than in the previous year.

According to this year’s projection data, the total annual emissions budget set out in the Federal Climate Action Act for the years 2021 to 2030 would be met with a buffer of 81 Mt CO₂-eq. In its review of the data, the Expert Council concludes that the projection data tend to underestimate emissions up to 2030. However, in the Expert Council’s assessment, the extend of underestimation is approximately equal to the buffer reported in the 2025 projection data. Given the existing uncertainties, the Expert Council, in line with its mandate, finds that the total GHG emissions for the years 2021 to 2030 neither exceed nor fall short of the corresponding amount permitted under the Climate Action Act. Therefore, as per Section 8 (1) KSG, there is no subsequent exceedance, and the mechanism for further policy action is not triggered.

“The results of our review show that the emissions budget will not be exceeded by 2030. But without the buffer that has built up in the years 2021 to 2024 due to coronavirus and the weak economy, amongst other factors, there is a high probability that the budget would have been significantly overshot by the end of 2030,” says Hans-Martin Henning, Chair of the Expert Council. “In addition, according to the projection data, the national commitments under the European Effort Sharing Regulation are not met starting from 2024 onwards. They show an increased target gap for 2030 compared to the previous year. The overarching 65‑per‑cent‑target for 2030 would also not be reached.”

Expert Council calls for further development of the target architecture in the Climate Action Act

For the years beyond 2030, the projection data show a significant and progressively increasing breach of targets. The land use, land use change, and forestry (LULUCF) sector is no longer shown as a carbon sink in the projection data. Instead, it is shown as a source of emissions, a trend that is expected to continue until 2045 and beyond. This is due to the poor condition of the forest. According to the projection data, without the LULUCF sector, emissions amounting to 204 Mt CO₂-eq. would remain in 2045. When the LULUCF sector is included, the residual emissions are even higher. As a result, the overarching goal of achieving climate neutrality by 2045 would be missed significantly.

To achieve climate neutrality, remaining residual emissions must be compensated by the carbon sink contribution of the LULUCF sector and by technical sinks. The potential of the LULUCF sector to once again become a carbon sink is uncertain at this time, and the conditions under which it might do so are not yet clear. The use of negative emission technologies is also subject to numerous uncertainties. In light of the projected target breaches and the unpredictable developments in the field of carbon sinks, the Expert Council recommends clarifying and supplementing the target architecture of the Climate Action Act in its report. In particular, a long-term strategy should be developed promptly to clarify the interplay between residual emissions, the LULUCF sector, and technical sinks in achieving climate neutrality in the target year 2045 and on the way there. “The Climate Action Act currently does not contain a specific target for residual emissions in 2045, the federal government has not yet defined the target for technical sinks, and the target for LULUCF is missed by a wide margin in the projection data,” explains Council member Marc Oliver Bettzüge, adding: “It is therefore not clear at this stage how the German government intends to achieve climate neutrality by 2045.” The Expert Council therefore recommends a swift clarification and calls for a consistent climate action policy framework.

Upcoming climate action programme should target identified problem areas

Even if no corrective policy action is required due to a second target shortfall, the Climate Action Act mandates that a climate action programme must be adopted within the first twelve months of the legislative period. This would be by the end of March 2026. According to the law, this programme must fully address the identified target shortfalls up to 2040. In the view of the Expert Council, the projected failure to achieve climate neutrality by 2045 should also be considered, even if the latter is not explicitly required as part of a climate action programme. The Expert Council identifies in its report a number of areas that warrant particular attention in the climate action programme – including measures in the transport and buildings sectors, the implementation of the second European Emissions Trading System (EU ETS 2), as well as measures in the LULUCF sector and the deployment of technical sinks.

In its report, the Expert Council also compares these areas of action with the announcements made in the coalition agreement. “The coalition agreement does not generate any significant impetus for achieving the 2030 target,” states Deputy Chair Brigitte Knopf. “Furthermore, the coalition agreement does not explicitly address the key problem areas and remains vague in many passages. We therefore recommend that the upcoming climate action programme should not only ensure the achievement of the 2030 target but also explicitly focus on the identified areas of action and the long-term achievement of climate neutrality.”

Download press release  [PDF, 81 kB]

The Council of Experts on Climate Change (ERK) is an independent panel of five experts from different disciplines. It was appointed in September 2020 and is mandated by Sections 11 and 12 of the Federal Climate Action Act (KSG). The panel consists of the five members Prof. Dr. Hans-Martin Henning (Chairman), Dr. Brigitte Knopf (Deputy Chair), Prof. Dr. Marc Oliver Bettzüge, Prof. Dr. Thomas Heimer, and Dr. Barbara Schlomann.

For more information about the Council of Experts on Climate Change and their publications, please visit https://www.expertenrat-klima.de/en/.
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