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EUROPEAN COMMISSION

Brussels, 27.10.2026

COM(2026) 730 final

2026/0336 (COD)

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

establishing a framework to enhance climate resilience and amending Regulation (EU)

2018/1999 (European Climate Resilience Law)

{SEC(2026) 730 final} - {SWD(2026) 730 final} - {SWD(2026) 731 final} -

{SWD(2026) 732 final}

(Text with EEA relevance)

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EXPLANATORY MEMORANDUM

1. CONTEXT OF THE PROPOSAL

• Reasons for and objectives of the proposal

Climate change is and will remain the defining challenge of the coming decades and beyond.

Current global mitigation commitments are projected to result in around 2°C of global

warming by 2050 and around 3°C by the end of the century.1 This indicates that Europe is

expected to warm by an average of 4 to 5°C2, despite the 1.5°C temperature threshold set by

the Paris Agreement adopted under the United Nations Framework Convention on Climate

Change (the ‘Paris Agreement’)3.

Climate change is causing increasing economic, fiscal, social and environmental impacts

across the Union. Adverse climate impacts are expected to intensify in frequency, magnitude

and duration under the projected warming levels, bringing about adverse consequences for

social and territorial cohesion, health, security, prosperity and intergenerational fairness.

Without effective adaptation, climate impacts are expected to trigger significant sectoral,

regional and systemic disruptions. Strengthening climate resilience and adapting to

unavoidable climate impacts has therefore become urgent and essential.

The first European climate risk assessment4 and the 2024 communication on managing

climate risks5 identified the most urgent climate risks across Europe. They concluded that

progress in integrating climate resilience and adaptation into Union and Member States

policies is uneven and that it is not keeping pace with accelerating climate change. The eighth

environment action programme (8EAP) mid-term review6 also concluded that the EU and its

Member States must strengthen preparedness and improve the management of climate risks.

The Commission, in its latest climate action progress report (CAPR), stressed that climate

resilience urgently needs to become an integral part of all EU policies because climate change

is undermining the EU’s prosperity, competitiveness and security.

The European Scientific Advisory Board on Climate Change has stated that existing climate

resilience and preparedness across EU and Member States policies and actions remain

insufficient, fragmented, largely incremental, often coming too late, occasionally incoherent,

and not yet commensurate with the scale, pace and complexity of increasing climate risks.

Regulation (EU) 2021/1119 of the European Parliament and of the Council (European

Climate Law) establishes a legal foundation for horizontal climate adaptation, setting out a

general obligation to ensure continuous progress in enhancing adaptive capacity,

strengthening resilience and reducing vulnerability to climate change. It requires the

Commission to adopt and regularly review a Union adaptation strategy, and the Member

1 IPCC, 2023: Sections. In: Climate Change 2023: Synthesis Report. Contribution of Working Groups I,

II and III to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Core

Writing Team, H. Lee and J. Romero (eds.)]. IPCC, Geneva, Switzerland, pp. 35-115. 2 European Scientific Advisory Board on Climate Change (2026), ‘Strengthening resilience to climate

change in Europe recommendations for an effective EU adaptation policy framework’. 3 OJ L 282, 19.10.2016, p. 4. 4 European Environment Agency, European climate risk assessment – Executive summary, Publications

Office of the European Union, 2024. 5 Communication from the Commission to the European Parliament, the Council, the European

Economic and Social Committee and the Committee of the Regions: Managing climate risks -

protecting people and prosperity, (COM(2024) 91 final). 6 Communication from the Commission to the European Parliament, the Council, the European

Economic and Social Committee and the Committee of the Regions: on the 8th Environment Action

Programme Mid-Term Review, (COM (2024) 123 final).

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States to adopt, implement and update national adaptation strategies and plans, based on

robust climate change and vulnerability analyses, progress assessments and indicators, and

guided by the best available and most recent scientific evidence. In addition, it sets the

requirements for assessing progress on adaptation.

The Commission’s 2023 assessment of Member States’ adaptation progress under the

European Climate Law found that, although national adaptation frameworks were largely in

place, major weaknesses remained in their operationalisation and implementation. The

Commission’s 2023 guidelines on Member States’ adaptation strategies and plans have

supported Member States, to a limited extent, in developing and reviewing their policy

frameworks. However, its non-binding nature has limited its ability to facilitate addressing

persistent gaps in these policy frameworks such as on national ownership, political

commitment, coordination, administrative and technical capacity and financial resources.

In the absence of a common framework for managing climate risks, it has become apparent

that preparedness for climate impacts and risks remains incoherent, fragmented and

insufficient across the EU economy and society. Member States currently rely on different

assumptions on climatic developments now and in the future, and use variable warming

trajectories and scenarios, as well as assessment cycles. The approaches are also based on

diverse sectoral coverage. As a result, climate risks are identified and managed inconsistently,

leading to inconsistent integration of climate resilience considerations across sectors, uneven

levels of preparedness, and difficulties in effectively addressing and communicating shared,

and transboundary climate risks. These differences reduce comparability, hinder coordination,

and limit efficient integration of climate resilience into policies and investment decisions.

This undermines productivity, growth, fiscal sustainability and financial stability.

To address the shortcomings, this proposal aims to establish a common framework for climate

resilience with an overall objective for the Union and Member States to continuously enhance

climate resilience for short-, medium- and long-term climate risks.

To achieve this objective, the proposal introduces the following core elements for making

anticipatory climate risk management the norm across Europe, at all levels of government:

(a) a reference global warming trajectory for risk assessments, planning and decision-

making, contextualised for different parts of Europe through the new European

Climate Viewer;

(b) identification of policy risk owners;

(c) improved and more regular climate risk assessments;

(d) a single strategic plan on climate resilience by the Commission and Member States;

(e) simpler and more effective monitoring and progress tracking at Member State and

Union-level.

The proposal provides a common set of rules for identifying, assessing and managing climate

risks across the Union. The proposed Union-level indicators are a starting point. Further

indicators may be added over time, drawing on scientific evidence, international

developments and experiences by Member States. During the transitional period, while the

Commission (Eurostat) develops the proposed Union-level indicator on economic losses

attributable to climate change, data collection for the existing indicator on climate-related

economic losses and fatalities will continue as defined under the 8th environment action

programme. From 2030 onwards, it is envisaged that Eurostat will collect data for the

economic losses attributable to climate change indicator, replacing the existing indicator on

climate-related economic losses and fatalities.

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By promoting a more coherent and coordinated approach to climate resilience, the proposal

aims at improving preparedness across the Union, facilitating the management of

transboundary climate risks and strengthening the resilience of Member States' economies and

societies. Although the private sector is not directly subject to the proposal, it also seeks to

improve private sector awareness of climate risks and capacity to apply climate resilience

solutions. Overall, the proposed Regulation would contribute to strengthening the Union's

long-term competitiveness, prosperity, security and the safety and wellbeing of its people.

The initiative responds to the requests and reports by the European Parliament7, the Council

of the EU8, the Committee of the Regions9, and the European Court of Auditors10 for a more

coherent and systematic approach to climate resilience. It also responds to the conclusions of

the Environment Council of December 2025, welcoming the development of an EU

Framework for Climate Resilience11 and calling for proactive integration of climate resilience

across policies, sectors and governance levels.

• Consistency with existing policy provisions in the policy area

The proposal complements and strengthens the existing Union framework for climate

adaptation, building primarily on the European Climate Law. Climate adaptation is the

process of adjusting to actual or expected climate and its impacts, in order to strengthen

climate resilience, for which the proposal contributes to ensuring the implementation of the

global goal on adaptation set in Article 7 of the Paris Agreement and the obligations on

adaptation to climate change set in Article 5 of the European Climate Law. The

proposal remains fully consistent with the objectives and obligations of existing Union

climate acquis.

The proposal aims to reduce administrative burden through more uniform application of rules,

streamlining and improving policy coherence. It would complement the existing framework

by setting a common, science-based reference global warming trajectory to inform climate

risk assessments and climate resilience planning. Member States could use it to develop

nationally relevant climatic scenarios, reflecting their specific circumstances. The proposal

aims at encouraging public authorities to consider climate resilience, facilitating continuous

progress in enhancing adaptive capacity, strengthening resilience and reducing vulnerability

to climate change in accordance with Article 7 of the Paris Agreement and in compliance with

the obligations under the European Climate Law.

The proposal’s core elements, including the reference global warming trajectory and the

identification of policy risk ownership, would put the European Climate Law's existing

climate adaptation requirements into practice. The proposal also introduces more actionable

requirements through Union and national strategic plans on climate resilience. This should

result in coherent strategic plans on climate resilience at Union and Member States level

covering also the requirements for adopting adaptation strategies and plans under the

European Climate Law. Member States can meet their planning obligations under the

proposed law and the European Climate Law through the preparation of one single

7 European Parliament resolution of 19 September 2024 on the devastating floods in central and eastern

Europe, the loss of lives and the EU’s preparedness to act on such disasters exacerbated by climate

change, (2024/2817(RSP)). 8 Council conclusions of 17 June 2024 on the 8th Environmental Action Programme Mid-term Review. 9 Opinion of the European Committee of the Regions of 11 December 2025 on Climate adaptation in

cities and regions: building the European Climate Adaptation Plan. 10 European Court of Auditors, Special report 15 on Climate adaptation in the EU: Action not keeping up

with ambition. 11 Council conclusions of 16 December 2025 on Europe’s Environment 2030 - Building a more climate

resilient and circular.

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consolidated plan. Strategic plans would also facilitate assessments on progress at Union and

national level under the European Climate Law, thereby promoting more consistent,

comparable, aggregable and mutually supportive tracking of progress. The proposal will not

introduce new, additional progress assessment requirements.

The Commission does not propose to introduce new reporting requirements. Instead, it builds

on the existing obligations under Article 19 of Regulation (EU) 2018/1999 of the European

Parliament and of the Council12 (Governance Regulation) requiring Member States to report

on national climate adaptation action. Amendments to the Governance Regulation are

however needed to ensure reporting requirements are aligned with this proposal.

To ensure a streamlined and improved approach, the provisions of the proposal would enable

consolidating four existing and currently fragmented planning elements into a single planning

instrument.

The proposal simplifies existing adaptation-related obligations under the Governance

Regulation. Article 4 of the Governance Regulation currently requires that Member States

incorporate adaptation goals into their National Energy and Climate Plans (NECPs), and

Annex IV to address adaptation policies and measures in long-term strategies (LTS) and fulfil

related progress reporting obligation as set out in its Article 17.

To avoid duplication and to reduce administrative burden, the proposal sets out in its Article

14 provisions deleting any overlapping requirements from the Governance Regulation. The

information on climate resilience would continue to be reported under Article 19 of the

Governance Regulation. Required amendments of climate resilience related reporting

obligations would be secured through the planned review of the Governance Regulation.

To strengthen the integration of climate resilience into economic, social and environment

policy coordination, and investment priorities, the Commission would assess Member States’

progress on climate resilience in the context of the European Semester, drawing on

information reported by Member States pursuant to Article 19 of the Governance Regulation.

• Consistency with other Union policies

The proposal is linked to many sectoral EU policies and initiatives because they are all

exposed to climate risks and impacts. Climate resilience has so far been integrated in a

fragmented and incremental way, raising concerns about overall policy coherence and

reflecting the lack of an overarching and coherent framework to guide action. As a result,

climate-related risks in many sectoral policy areas are, without significant additional action,

projected to increase.

Relevant EU initiatives and instruments include the Directive on requirements for budgetary

frameworks of the Member States13; the EU Taxonomy Regulation14; the surveillance

mechanisms for tracking climate risks used by the European Central Bank, European

Systemic Risk Board, and European Banking Authority; the Critical Entities Resilience

Directive15; the Risk-Preparedness Regulation16; certain tools of the common agricultural

policy; EU Nature Restoration Regulation17; the Marine Strategy Framework Directive18; the

12 OJ L 328 21.12.2018, p. 1. 13 OJ L, 2024/1265. 14 OJ L 198, 22.6.2020, pp. 13–43. 15 OJ L 333, 27.12.2022, pp. 164–198. 16 OJ L 158, 14.6.2019, pp. 1–21. 17 OJ L, 2024/1991, 29.7.2024. 18 OJ L 164, 25.6.2008, pp. 19–40.

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EU Occupational Safety and Health (OSH) Framework Directive19; the Union’s

environmental assessment instruments; the Water Framework Directive20; the Floods

Directive21, the Water Reuse Regulation22, the European Ocean Pact23; the common fisheries

policy24; the LIFE programme and strategies such as the preparedness Union strategy; EU

ports strategy25; TEN-T Regulation26, EU medical countermeasures strategy27; EU forest

strategy28; the integrated wildfire risk management strategy29; the EU soil strategy30; strategy

for European life sciences31; the European water resilience strategy32; the New European

Bauhaus33 and EU urban environmental frameworks (Green City Accord and European Green

Capital and European Green Leaf awards).

The Commission’s proposal for the next EU budget (multiannual financial framework) of July

2025 recognises the need for EU funding to promote preparedness and resilience, including

climate risks. This is reflected in the recitals and objectives of the acts that will govern the

different funds, including the National and Regional Partnership Plans, the European

Competitiveness Fund, Horizon Europe and the Union Civil Protection Mechanism. The

proposed Performance Regulation lists intervention fields for dedicated climate resilience

measures. One of the three co-efficients used for tracking spending towards the overall 35%

climate and environment target will cover climate change adaptation and resilience. In

addition, Article 33(2)(d) of the Financial Regulation34 requires that “programmes and

activities shall, where feasible and appropriate in accordance with the relevant sector-specific

rules, be implemented to achieve their set objectives without doing significant harm to the

environmental objectives” and specifically lists climate change adaptation as one of the

objectives.

The objective of the 2026 European Semester package was to boost competitiveness, secure

strategic autonomy, increase resilience, and strengthen preparedness while maintaining fiscal

sustainability. The EU Semester country reports pinpoint specific climate resilience issues to

be addressed in individual Member States, e.g. climate resilience governance, inadequate

insurance, need for investments, climate-proofing of infrastructure, and use of nature-based

solutions. Furthermore, the European Semester country-specific recommendations inform

priorities of the future national and regional reforms and investments of individual Member

States. In the 2026 European Semester, several Member States received country-specific

recommendations on climate resilience or on reducing the climate protection gap, bringing the

total number of Member States that have received climate-resilience-related country-specific

recommendations in recent years to 16.

Although climate resilience is covered by a substantial regulatory and policy lineup, it is often

addressed only in general and inadequate terms, with little evidence of implementation, partly

19 OJ L 183 29.6.1989, p. 1. 20 OJ L 327, 22.12.2000, pp. 1–73. 21 OJ L 288, 6.11.2007, pp. 27–34. 22 OJ L 177, 5.6.2020, pp. 32–55. 23 COM/2025/281 final. 24 OJ L 354 28.12.2013, p. 22. 25 COM/2026/112 final. 26 OJ L, 2024/1679, 28.6.2024. 27 COM/2025/529 final. 28 COM/2021/572 final. 29 COM/2026/330 final. 30 COM/2021/699 final. 31 COM/2025/525 final. 32 COM/2025/280 final. 33 COM/2021/573 final. 34 OJ L, 2024/2509, 26.9.2024, ELI: http://data.europa.eu/eli/reg/2024/2509/oj.

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due to a lack of data collection. There are differences in scope, objectives, climate projections

used, responsibilities, planning, and monitoring approaches in the sectoral policy areas, which

also lead occasionally to contradictions.

The proposal aims to establish a framework to reduce fragmentation in governance and policy

approaches at national and EU level, improve and align preparedness for climate impacts and

risks across sectors and policy areas, and enable the tracking and assessment of progress. A

climate risk-based governance model that addresses sectoral preparedness gaps and cross-

sectoral coordination will be more effective and increase the overall resilience of the EU

economy and population.

2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY

• Legal basis

The legal basis for the proposal is Article 192(1) of the Treaty on the Functioning of the

European Union (TFEU). In accordance with Articles 191 and 192(1) TFEU, the European

Union must contribute to the pursuit of the following objectives: (i) preserving, protecting and

improving the quality of the environment; (ii) promoting measures at international level to

deal with regional or worldwide environmental problems; and in particular (iii) combating

climate change.

• Subsidiarity (for non-exclusive competence)

Climate change and related impacts and risks are inherently transboundary in nature. Many

climate risks, including disruptions to interconnected energy systems and critical

infrastructure, supply chains, ecosystems and financial systems, extend across national

borders and cannot be effectively addressed by national and local action alone. Coordinated

action at Union-level can complement and reinforce national, regional and local measures and

improve the overall effectiveness of climate resilience efforts by enabling the integration of

resilience policies and measures in key sectors, governance levels and EU policies.

Climate impacts and risks can also undermine the effective delivery of EU policies including

the functioning of the EU single market as well as the Union’s ability to uphold its

fundamental rights, pursue its international obligations and promote more ambitious

approaches internationally. Policy intervention at the EU level, together with national,

regional and local action, is necessary to achieve sufficient levels of systemic, EU-wide

climate resilience and preparedness levels effectively and efficiently.

The magnitude and complexity of the challenge, and the fact that climate change affects many

policy areas that are shared between the EU and its Member States, requires an all-of-

government approach that includes intervention at the EU policy level. Complementing

different national policies and rules, EU-level action is needed for promoting a science-based

understanding and more coherent approach to climate resilience at national and subnational

level and across policy areas, thereby effectively reducing transnational, cross-border and

systemic risks.

Coordination of climate action is necessary at EU level and EU action is justified on the

grounds of subsidiarity. In addition, coordinated action at EU level can achieve economies of

scale and reduce administrative and implementation costs by promoting common

methodologies, shared tools and more efficient exchange of information and good practices.

• Proportionality

The proposal does not go beyond what is necessary for achieving the objective of enhancing

climate resilience. The proposal establishes a common framework for strengthening climate

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resilience and addressing climate risks across the Union. It does not prescribe specific sector

or national policies or measures, leaving appropriate democratic processes at EU and Member

State level the flexibility to determine the policies and measures needed to achieve the

framework’s objective, considering their specific circumstances and existing regulatory

frameworks.

• Choice of the instrument

The objective of the proposal can best be pursued through a Regulation. This will ensure

direct applicability of the provisions. A Regulation ensures uniform, direct and simultaneous

application of these requirements across the Union. This ensures swift action on fast-rising

climate impacts and risks and promotes a coherent approach to climate resilience governance,

including climate risk assessment and planning, while avoiding delays and inconsistencies

resulting from Member States needing to turn the EU rules into national law.

3. RESULTS OF EX- POST EVALUATIONS, STAKEHOLDER

CONSULTATIONS AND IMPACT ASSESSMENTS

• Ex- post evaluations/fitness checks of existing legislation

Not applicable.

• Stakeholder consultations

In line with the Better Regulation guidelines, a number of consultation activities were carried

out to: (i) raise stakeholder and public awareness of the initiative; (ii) gather their input on the

proposed aspects of the new framework; and (iii) gather any additional views or suggestions

they may have.

The Call for Evidence consultation was open from the 24 July 2025 to 4 September 2025 on

the Commission’s ‘Have your say’ website resulting in 233 responses passing the suitability

check. The overall response showed broad support for the EU framework, with some

disagreements focusing on the depth of the EU legal obligations versus subsidiarity. The five

most frequent priorities (mentioned in ≥60 % of responses) were related to the following:

• stable, predictable, long-term EU funding and blended-finance tools for adaptation.

• harmonised risk-assessment standards with shared climate scenarios.

• resilience-by-design criteria for all public spending and procurement.

• nature-based solutions (NbS) as default first line of defence.

• systematic integration of health, incl. heat-health, into all plans.

The public consultation was open from 1 December 2025 to 23 February 2026, resulting in

675 responses submitted through the EU survey portal with 670 passing the suitability check.

Additionally, a total of 31 individuals or companies complemented their responses or

contributed separately their views through position papers and additional material35. These

35 Out of the 31 companies/individuals that sent position papers/additional material, 1 of them was a

duplicate, while 3 of them were a PDF version of responses already inputted in the EU Survey platform.

Two additional survey responses were also sent and were considered for the open-ended analysis;

however, they were not included in the quantitative analysis as they were shared separately and were

not part of the consolidated dataset taken from the EU Survey platform. Including these responses

would have required manual data entry which would have had minimal impact on the overall findings.

Other position papers/material were whole reports where only their executive summary was analysed

for the purposes of this summary. In cases where the position papers were in a different language than

English, these were translated using a machine translator and were then analysed.

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documents were taken into account, where relevant, or as additional views to the specific

topics of the consultation. The responses show that, the inclusion of certain elements in a

legislative proposal received broad support, such as having a common reference warming

trajectory (58%) or more harmonised and comprehensive climate risk assessments (72%).

Additional consultation activities were carried out, which included discussions with

representatives in the Working Party on the Environment (WPE) of the Council of the

European Union, the European Climate Policy Group (ECPG), and the Working Group on

Adaptation (WGA) under the Climate Change Committee. Engagement with the European

Parliament was carried out through the Committee on Environment, Public Health and Food

Safety (ENVI), complemented by a series of bilateral meetings and participation in relevant

parliamentary events.

Dialogues were held with the Committee of the Regions and the European Economic and

Social Committee. In addition, exchanges with other EU bodies, such as the European

Environment Agency (EEA), European Investment Bank (EIB) and the European Scientific

Advisory Board on Climate Change (ESABCC) also informed the proposal.

Other activities which informed the proposal included the work carried out by the Reflection

Group on Mobilising Climate Resilience Financing, the Industrial Forum, the EU Mission on

Adaptation to Climate Change, the Covenant of Mayors and the Climate Pact.

• Collection and use of expertise

See above.

• Impact assessment

The impact assessment accompanying this proposal has been prepared and developed in line

with the applicable Better Regulation guidance. After having resolved the issues raised in the

Regulatory Scrutiny Board’s negative opinion issued on 22 May 2026, the impact assessment

received a positive opinion with reservations on 7 September 2026.

The comments from the Board were addressed as follows:

(1) To present more clearly the evidence behind the problem of physical preparedness, the

Section 2 of the impact assessment was streamlined and examples from EUCRA were added

to better illustrate the gaps in physical preparedness across sectors/policies and Member

States.

(2) To demonstrate better the causal link between options and expected effects, including

possible secondary consequences for private actors, more details on the methodology to assess

residual risk and risk tolerance were added, to better explain how risk owners would consider

and decide on them. For private sectors the evidence was added wherever possible.

(3) To present the costs and the benefits in sufficiently clear way, Section 6 was improved

to illustrate more clearly the costs and benefits of the different policy options. Further

breakdown of the costs for the Navigator of tools and Climate Viewer was added to the text.

Annex 3, including the table on burden reduction, has been updated to reflect the changes in

the text. The text throughout the section was also improved to better illustrate which

costs/benefits stem directly from the proposal and which ones are expected from follow-up

interventions.

(4) To give a better assessment of the proposal’s coherence with the post-2030 climate

and energy package. This includes potential overlaps, unnecessary administrative burden and

enforcement, additional text was added to Section 8 on the links between the proposed

Framework, the European Climate Law and the Governance Regulation. The detailed

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description of those envisaged interactions, simplification of various aspects (planning,

reporting, etc) and reduction of duplications were presented in Annex 14.

The impact assessment identified the overall problem to be uneven and insufficient

preparedness of the European economy and society for climate change. It broke the overall

problem down into three main elements: (i) fragmented climate resilience in the EU and its

Member States (problem 1); (ii) an unprepared private sector (problem 2); and (iii) an

unprepared population (problem 3).

It identified several problem drivers including those relating to institutional, policy and

governance barriers, methodological, evidence and informational barriers, information and

know-how barriers, market failures and behavioural barriers.

The impact assessment addressed three policy options, differing in level of intervention and

balance between mandatory and voluntary measures. Each policy option included core

elements such as common objectives; a reference warming trajectory as a common baseline

for decisions; horizontal principles (such as ‘duty to consider’, ‘risk ownership’ and ‘climate

resilience by design’); climate risk assessments; planning and implementation; progress

monitoring; and horizontal enablers such as supporting tools.

The impact assessment concluded that for the core elements a Regulation would be preferred.

It would establish inter alia a common reference global warming trajectory and a requirement

to prepare regular and harmonised climate risk assessments. On planning, requirements would

be simplified, as Member States can prepare only one strategic plan on climate resilience

covering the current national adaptation strategies and plans under the European Climate Law.

The climate adaptation planning related requirements are to be removed under the

Governance Regulation. The climate resilience related reporting requirements will remain

under the Governance Regulation, avoiding additional reporting obligations.

This combination of measures under the preferred policy option would result in the best

balance between reducing administrative burden and preserving flexibility for Member States.

It would also achieve a favourable cost-benefit ratio in the short and long term, while ensuring

a more anticipatory approach that allows for the EU and its Member States to be more climate

resilient.

The impact assessment includes the consistency check of Article 6(4) of the European

Climate Law, which requires the Commission to assess the consistency of any EU draft

measure or legislative proposal with the European Climate Law’s objectives, such as the EU’s

climate-neutrality objective. It concludes that the initiative would not directly result in actions

generating greenhouse gas emissions. It would however help minimise the vulnerabilities of

climate-sensitive decarbonisation pathways such as through land carbon sinks and

hydropower generation and seek to minimise its key external problem driver by encouraging

progress towards climate neutrality. The consistency check deemed the initiative to be

consistent with the climate-neutrality objective set out in Article 2(1) of the European Climate

Law and with the EU’s 2030 and 2040 climate targets.

• Regulatory fitness and simplification

In line with the Commission’s commitment to Better Regulation, the proposal has been

prepared inclusively, based on transparency and continuous engagement with stakeholders.

Simplification has been a guiding principle throughout the preparation of the proposal that

sets only essential requirements while allowing Member States maximum flexibility in

implementation. The proposal introduces a limited number of forward-looking elements,

building on scientific developments and existing best practices. It also reduces administrative

burden and duplication by consolidating existing adaptation planning instruments, namely

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national adaptation strategies and plans, and the adaptation-related elements currently

required under national energy and climate plans (NECPs) and long-term strategies, into

climate resilience strategic plans, without affecting sector-specific planning requirements.

Corresponding planning requirements related to climate adaptation under the Governance

Regulation are discontinued, and the remaining reporting obligation is streamlined to meet the

needs of the new Framework.

• Fundamental rights

The proposal respects the fundamental rights and observes the principles recognised by the

Charter of Fundamental Rights of the European Union. The proposal would contribute to the

objective of a high level of environmental protection in accordance with the principle of

sustainable development as laid down in Article 37 of the Charter of Fundamental Rights of

the European Union36.

4. BUDGETARY IMPLICATIONS

The legislative financial and digital statement included in the proposal shows the detailed

budgetary implications and the human and administrative resources required.

The implementation of the proposal would require the Commission, the European

Environment Agency, and the European Insurance and Occupational Pensions Authority to

ensure additional resources.

5. OTHER ELEMENTS

• Implementation plans and monitoring, evaluation and reporting arrangements

To avoid additional administrative burden, the proposal does not introduce new requirements

for progress assessment or reporting. The existing arrangements for tracking progress under

the European Climate Law and the Governance Regulation would, however, ensure that the

implementation of the proposal would be monitored closely. The proposed Regulation would

be subject to a review in 2033.

• Detailed explanation of the specific provisions of the proposal

Article 4 and Annex I set a scientifically solid and reliable reference global warming

trajectory to provide a common anchor for planning and implementing decisions at all

governance levels. It may be updated, when necessary, based on scientific evidence.

Article 5 and Annex II require Member States and the European Environment Agency to

periodically identify major climate risks, assess their urgency and provide options for policy

action. This will contribute to more aligned national and EU assessments of climate risk to

provide evidence for climate risk management options and improve the comparability of the

risks under various climate scenarios.

Articles 6 and 7 and Annex IV require the Commission and the Member States to adopt

strategic plans on climate resilience setting objectives and measurable targets, where relevant,

for each policy area of Union-wide relevance for climate resilience set out in Annex III. In

addition, the plan is meant to set measures for addressing major climate risks identified in

climate risk assessments, as well as indicating the authorities responsible for addressing each

of the major climate risks (policy risk owner). Member States would need to indicate in their

national strategic plans how public authorities consider climate resilience in their decisions.

36 OJ C 326, 26.10.2012, p. 391.

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The Commission should assess the Member States’ progress on climate resilience every two

years through the European Semester.

Article 9 requires the Commission to ensure the availability of an online platform to facilitate

compliance with the obligations of the proposal and to facilitate public access to climate risk

and resilience information. The platform is meant to provide a central entry point to climate

risk and resilience support services and solutions, including online tools that help to better

identify and understand specific climate risks. The platform will also further streamline EU-

level knowledge sharing and provide examples of effective climate resilience solutions for

different sectors and geographies, building on the learnings from successful case studies and

projects. This includes the Mission on Adaptation to Climate Change and the European

Climate Adaptation Platform Climate-ADAPT. It responds to recommendation No.2 of the

Special Report No. 15/2024 of the European Court of Auditors and related recommendations

53 and 56 by the Council of the European Union.

Article 10 contains provisions on statistics on loss of life and economic losses attributable to

climate change.

Article 11 contains provisions on the role of the European Environment Agency.

Article 14 contains amendments to the Governance Regulation. It would remove the climate

adaptation planning related provisions from Governance Regulation, as proposed in Article

14. The amendments also respond to the European Court of Auditors’ Recommendation No. 1

of the Special Report No. 15/2024 and related recommendation 54 by the Council of the

European Union to address weaknesses identified in Member States’ reporting on climate

adaptation.

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2026/0336 (COD)

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

establishing a framework to enhance climate resilience and amending Regulation (EU)

2018/1999 (European Climate Resilience Law)

(Text with EEA relevance)

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,

Having regard to the Treaty on the Functioning of the European Union (TFEU), and in

particular Article 192(1) thereof,

Having regard to the proposal from the European Commission,

After transmission of the draft legislative act to the national Parliaments,

Having regard to the opinion of the European Economic and Social Committee1,

Having regard to the opinion of the Committee of the Regions2,

Acting in accordance with the ordinary legislative procedure,

Whereas:

(1) Climate change is already causing widespread and increasingly severe and negative

impacts across the Union. It is affecting natural and human systems, including

ecosystems, infrastructure, water resources, energy, food systems, public health,

cultural heritage and economic activity.

(2) The Union has set, in Regulation (EU) 2021/1119 of the European Parliament and of

the Council3 (‘European Climate Law’), a binding objective of economy-wide climate

neutrality by 2050 and binding intermediate Union climate targets for 2030 and for

2040. It has become increasingly clear, though, that global warming will, at least

temporarily, exceed the 1.5°C temperature threshold of the Paris Agreement4 adopted

under the United Nations Framework Convention on Climate Change. Europe, which

has been the fastest-warming continent in recent decades, could see average

temperatures rise by 4°C to 5°C by 2100 compared to the pre-industrial average

European temperature5.

(3) The impacts and risks associated with climate change are expected to intensify in

frequency, magnitude and duration. This is threatening to increasingly undermine

Europe’s social and territorial cohesion, its security and prosperity, the health and

1 OJ C [...], [...], p. [...] 2 OJ C [...], [...], p. [...] 3 Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 establishing

the framework for achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU)

2018/1999 (OJ L 243 9.7.2021, p. 1, ELI: http://data.europa.eu/eli/reg/2021/1119/oj). 4 OJ L 282, 19.10.2016, p. 4. 5 European Scientific Advisory Board on Climate Change, Strengthening resilience to climate change –

Recommendations for an effective EU adaptation policy framework, 17 February 2026.

EN 13 EN

well-being of its people, and intergenerational fairness. Furthermore, climate change is

increasingly impacting biodiversity and disrupting vital ecosystem functions and

services. These impacts can also deepen existing inequalities, disproportionately affect

people in vulnerable situations and those with fewer resources to adapt.

(4) EU-wide economic losses from weather- and climate-related extremes have risen

significantly in recent years, disrupting supply chains, reducing productivity and

undermining fiscal stability. Furthermore, climate change has driven biodiversity loss

and disrupted vital ecosystem services.

(5) Climate impacts increasingly affect the entire Union and put core Treaty objectives at

risk. Many of these impacts have cross-border and transboundary dimensions and are

shared between Member States. River basins, seas, energy grids, transport networks,

supply chains, ecosystems, infectious disease pathways, financial systems, markets

and societies span national borders. More Union-wide coordinated action is urgently

required to tackle climate change-related risks and impacts effectively and in a cost-

efficient manner.

(6) The Union is, in line with its commitments under international agreements, committed

to stepping up efforts and contributing to the achievement of the global goal on

adaptation set out in Article 7 of the Paris Agreement, which aims to enhance adaptive

capacity, strengthen resilience and reduce vulnerability to climate change, with a view

to contributing to sustainable development.

(7) Regulation (EU) 2021/1119 provides for climate adaptation action at Union and

Member State level. Regulation (EU) 2018/1999 of the European Parliament and of

the Council6 (’Governance Regulation’) provides a framework for planning and

reporting on energy and climate policies. The provisions of those Regulations contain

objectives, targets, responsibilities, and measures but do not constitute a

comprehensive approach including consideration of climate risks across all Union

policies and Member States. Therefore, building on those Regulations, this Regulation

should streamline and consolidate their existing provisions on planning and reporting

and lay down more specific provisions aimed at improving the planning and

implementation of climate resilience measures throughout the Union and each

Member State.

(8) This Regulation does not alter obligations on climate resilience, risk management,

preparedness or adaptation in specific sectors or policy areas laid down in other Union

legal instruments. It is part of a comprehensive approach to managing risks and threats

across policy areas of Union-wide relevance for climate resilience, as set out in Annex

III and regarded to be crucial for maintaining vital societal functions, economic

activities, public health and safety, the environment, including disaster resilience,

resilience and protection of critical infrastructure and critical entities and continuity of

essential services. It does not affect Member States’ responsibilities for national

security or existing Union and national institutional arrangements concerning

preparedness and defence readiness. In particular, the requirements concerning climate

risk assessments and strategic planning should not interfere with time-critical activities

6 Regulation (EU) 2018/1999 of the European Parliament and of the Council of 11 December 2018 on the

Governance of the Energy Union and Climate Action, amending Regulations (EC) No 663/2009 and

(EC) No 715/2009 of the European Parliament and of the Council, Directives 94/22/EC, 98/70/EC,

2009/31/EC, 2009/73/EC, 2010/31/EU, 2012/27/EU and 2013/30/EU of the European Parliament and

of the Council, Council Directives 2009/119/EC and (EU) 2015/652 and repealing Regulation (EU) No

525/2013 of the European Parliament and of the Council (OJ L 328, 21.12.2018, p.1, ELI:

http://data.europa.eu/eli/reg/2018/1999/2023-11-20).

EN 14 EN

essential for national security, defence readiness and military preparedness, including

the timely implementation of defence-related investments and infrastructure projects

or protection of classified or security-sensitive information. Member States should

retain the necessary flexibility to address climate-related risks in such activities in

accordance with their operational requirements and existing sector-specific

arrangements.

(9) In order to improve planning for current and future climate risks, cross-border

comparability and overall policy coherence, a reference global warming trajectory

should be set. The trajectory will provide a common basis for expected global

warming levels. The reference trajectory should be used in combination with

systematic stress-testing with more adverse scenarios. Setting the trajectory does not

affect the binding objective set out in Regulation (EU) 2021/1119 of achieving climate

neutrality in the Union by 2050, in pursuit of the long-term temperature goal set out by

the Paris Agreement.

(10) To ensure the greater alignment of climate risk assessments, the assessments at Union

and Member State level should be based on the best available scientific knowledge

and local, traditional and Indigenous knowledge. Those risk assessments should also

take into account science-based alternative futures, extreme scenarios, and low-

probability high-impact climate risks, including risks associated with tipping points.

Depending on the specific circumstances of the Member State, relevant risk

assessments could include the risk assessments required under Decision

1313/2013/EU of the European Parliament and of the Council7, Directive 2007/60/EC

of the European Parliament and of the Council8, Directive (EU) 2022/2557 of the

European Parliament and of the Council9 and the EU comprehensive risks and threat

assessment. When carrying out the climate risk assessments, it is important to take into

account existing sector-specific risk assessments and preparedness mechanisms,

including those concerning critical dual-use infrastructure, where relevant, to avoid

duplication and ensure coherence with existing Union and national frameworks. To

ensure Union-level coherence, Member States should, when developing national

climate risk assessments, take into account at least the European climate risk

assessment when preparing the national climate risk assessments and reflect national

and regional circumstances, risk profiles and priorities.

(11) To make the climate resilience objective operational, strategic plans for climate

resilience should be adopted by Member States and the Commission, with the

participation of subnational public authorities in view of their important role in

preparedness and climate resilience, as well as response to adverse climate impacts.

These plans should be key instruments for achieving climate resilience objectives,

addressing major climate risks and defining tolerable levels of residual risks. To

promote just resilience, these plans should account for the specific circumstances of

people in vulnerable situations as well as communities, regions and territories

disproportionately impacted by climate risks, including to prevent discrimination,

7 Decision No 1313/2013/EU of the European Parliament and of the Council of 17 December 2013 on a

Union Civil Protection Mechanism (OJ L 347 20.12.2013, p. 924, ELI:

http://data.europa.eu/eli/dec/2013/1313/oj). 8 Directive 2007/60/EC of the European Parliament and of the Council of 23 October 2007 on the

assessment and management of flood risks (OJ L 288, 6.11.2007, p. 27, ELI:

http://data.europa.eu/eli/dir/2007/60/oj). 9 Directive (EU) 2022/2557 of the European Parliament and of the Council of 14 December 2022 on the

resilience of critical entities and repealing Council Directive 2008/114/EC (OJ L 333, 27.12.2022, p.

164, ELI: http://data.europa.eu/eli/dir/2022/2557/oj).

EN 15 EN

including on grounds of sex, racial or ethnic origin, disability, age or sexual

orientation.

(12) Climate resilience should be considered at an early stage in the preparation of policies,

plans, measures and other decisions at all levels of government that are materially

exposed to climate risks. When considering climate resilience, the reference global

warming trajectory set out in Article 4, and best available evidence regarding climate

risks, based on climate risk assessments carried out pursuant to Article 5 or other

relevant existing risk assessments should be key reference points. Member States

should, in their national strategic plans, set out the governance arrangements necessary

to embed and encourage climate resilience considerations in the exercise of public

functions.

(13) To avoid unnecessary administrative burden, the Union strategic plan on climate

resilience pursuant to Article 6 and the Member States’ strategic plans on climate

resilience pursuant to Article 7 may be adopted as single consolidated documents that

also address the relevant requirements under Article 5 of Regulation (EU) 2021/1119.

This would not in any way alter the obligation to fulfil all the requirements of

Regulation (EU) 2021/1119.

(14) In order to translate the Union’s climate resilience objective into coordinated and

coherent action, a Union strategic plan on climate resilience should be established as

the key instrument for addressing major climate risks at Union-level. The strategic

plan should also provide a strategic, anticipatory and action-oriented framework based

on the European climate risk assessments and other relevant risk assessments. It

should also strengthen preparedness, support timely investment and embed climate

resilience across Union decision-making. The Commission should include the

elements set out in Annex IV and take into account the Union-level indicators set out

in Annex V when preparing the Union strategic plan on climate resilience.

(15) To ensure policy coherence, each Member State should designate a central national

coordinating authority with a mandate appropriate to oversee the preparation and

implementation of the national strategic plan on climate resilience. To enhance policy

risk ownership, the national strategic plan should identify the competent public

authorities responsible for managing each of the major climate risks identified in

national climate risk assessments.

(16) In order to ensure that climate resilience is actually increased, the Member States

should set out in their strategic plans the measures that are needed to achieve the

objectives and targets set out in the plans and to address major climate risks. To ensure

that those measures deliver concrete improvements, those plans should contain

timeframes for implementing the measures and indicate investment needs, estimated

costs and sources of financing. The plans should, insofar as possible, use relevant

existing processes responsible for managing risks in the policy areas concerned, to

avoid duplication and ensure strengthened coherence across policy areas.

(17) To strengthen synergies with biodiversity objectives, including the management of

invasive species, and to ensure cost-effectiveness, nature-based solutions and

ecosystem-based adaptation should be promoted when deciding on measures in the

national strategic plans. To ensure synergies with other planning instruments, the

strategic plans should include an assessment of consistency with other relevant plans.

This may include national strategies for enhancing the resilience of critical entities,

national energy and climate plans, national restoration plans, national and regional

planning documents under the multiannual financial framework, river basin

EN 16 EN

management plans, flood risk management plans, marine strategies, maritime spatial

plans, national building renovation plans, social climate plans, disaster-risk

management instruments, and the relevant national water, health, forestry,

infrastructure, ocean, coastal, land-use and spatial planning strategies and plans and

cultural heritage risk management plans. In particular, Regulation (EU) 2024/1991

requires national restoration plans to take account of climate change scenarios and

synergies with climate change adaptation and disaster prevention, and to prioritise

restoration measures accordingly.

(18) In order to strengthen the link between climate risks and economic and social policies,

the Commission should assess the Member States’ progress on climate resilience

every two years, from 2028 onwards, in the context of the European Semester. The

European Semester process should be informed by the findings of those assessments

as well as by the information reported under Regulation (EU) 2018/1999.

(19) In order to assist the Union and Member States in complying with the requirements of

this Regulation, the Commission should ensure the availability of an online platform

to improve public access to information on climate risk and climate resilience, while

safeguarding classified and security-sensitive information. Union space data and

services, including Copernicus10, Galileo11, EGNOS12, GOVSATCOM13 and IRIS²14,

can support climate risk assessment, resilience measures and crisis preparedness.

(20) The European Environment Agency supports policy development at Union and

Member State level and in relevant global processes, offers analytical expertise and

provides and maintains an efficient reporting infrastructure for national and

international data flows. It informs decision-makers and the public about the state of

the environment in the Union and about climate change and wider sustainability

issues. For this reason, the European Environment Agency should, in view of its

expertise and infrastructure, assist the Commission and the Member States in

implementing the Regulation, as appropriate and in accordance with its annual work

programme.

(21) It is necessary to ensure that the technical information set out in the Annexes remains

up to date and continue to reflect scientific, technical and operational developments,

including developments reflected in the European climate risk assessments carried out

by the European Environmental Agency pursuant to Article 5(1) of this Regulation.

Therefore, the power to adopt acts in accordance with Article 290 TFEU should be

delegated to the Commission in respect of amending certain parts of the Annexes. The

relevant parts concern the reference global warming trajectory, requirements for

climate risk assessments and strategic plans on climate resilience and Union-level

indicators. The Commission should carry out appropriate consultations during its

preparatory work, including at expert level. These consultations should be conducted

in accordance with the principles laid down in the Interinstitutional Agreement on

Better Law-Making of 13 April 2016. In particular, the Commission should ensure

equal participation in the preparation of delegated acts, ensuring that the European

Parliament and the Council receive all documents at the same time as Member States'

experts, and that the experts systematically have access to meetings of Commission

expert groups dealing with the preparation of delegated acts.

10 https://eu-space.europa.eu/earth-observation/copernicus 11 https://eu-space.europa.eu/satellite-navigation/galileo 12 https://eu-space.europa.eu/satellite-navigation/egnos 13 https://eu-space.europa.eu/secure-connectivity/govsatcom 14 https://eu-space.europa.eu/secure-connectivity/iris2

EN 17 EN

(22) In order to improve the availability, consistency and comparability of statistics to

support evidence-based Union planning, the Commission (Eurostat) should compile

the necessary data from the Member States and other relevant data sources, and should

disseminate statistics on loss of life and economic losses attributable to climate change

by 31 December 2030 and annually thereafter.

(23) To avoid duplicative reporting and unnecessary administrative burden, reporting on

progress on climate resilience should continue under the existing requirements of

Regulation (EU) 2018/1999. In order to keep those reporting requirements fit for

purpose and up to date, they should be amended where necessary to align with this

Regulation and should require Member States to report only the essential information

on climate resilience. Existing information reported or otherwise made available

pursuant to Union sectoral legislation should be reused wherever it meets the relevant

information requirements. At the same time, those planning requirements that involve

including adaptation goals in integrated national energy and climate plans and

adaptation policies, and that involve including measures in the long-term strategies

should be removed from that Regulation in order to avoid duplicative requirements

overlapping with this Regulation. Regulation (EU) 2018/1999 should therefore be

amended accordingly.

(24) Climate risks frequently have transboundary and systemic effects and coordinated

action at Union-level is needed to effectively supplement and reinforce national

policies. Since the objective of this Regulation, namely to enhance climate resilience

throughout the Union, cannot be sufficiently achieved by the Member States but can

rather, by reason of the scale and effects, be better achieved at Union-level, the Union

may adopt measures, in accordance with the principle of subsidiarity as set out in

Article 5 of the Treaty on European Union. In accordance with the principle of

proportionality, as set out in that Article, this Regulation does not go beyond what is

necessary to achieve that objective.

(25) The Commission should monitor the application of this Regulation and report to the

European Parliament and to the Council in light of the experience acquired. Where

appropriate, the report should be accompanied by a legislative proposal to review the

functioning of this Regulation, including with respect to measures embedding climate

resilience considerations in the exercise of public functions,

HAVE ADOPTED THIS REGULATION:

Article 1

Subject matter

1. This Regulation establishes a framework to enhance climate resilience across the

Union and the Member States. It sets out a common climate resilience objective and

common parameters required for preparing for and addressing climate impacts. It

helps to ensure the implementation of the global goal on adaptation in Article 7 of

the Paris Agreement and the provisions on adaptation to climate change set out in

Regulation (EU) 2021/1119.

2. The framework established by this Regulation:

(a) sets out a common climate resilience objective and a reference global warming

trajectory that serves as a common baseline for framing climate resilience

decisions;

EN 18 EN

(b) sets out a common approach to assessing climate risks at Union and Member

State level;

(c) requires public authorities responsible for addressing major climate risks to be

identified;

(d) encourages public authorities to take into account the reference global warming

trajectory, national climate risk assessments and other relevant risk assessments

when exercising public functions, in particular budgeting, spatial planning and

impact assessment;

(e) provides for measures to be implemented so as to address major climate risks

and achieve climate resilience objectives;

(f) provides for cooperation between Member States to address transboundary

climate risks.

Article 2

Definitions

For the purposes of this Regulation, the following definitions apply:

(1) ‘climate adaptation’ means the process of adjusting to the actual or expected

climate and its impacts, to mitigate or avoid harm or exploit beneficial

opportunities;

(2) ‘climate resilience’ means the capacity of interconnected social, economic and

ecological systems to withstand a hazardous climate event, climate trend or

climate disturbance, responding or reorganising in ways that maintain their

essential function, identity and structure;

(3) ‘climate risk’ means the potential result of dynamic interactions between

climate hazards with the exposure and vulnerability of the human and

ecological systems affected;

(4) ‘public authorities’ means (a) state, regional or local authorities; (b) other

entities governed by public law; and (c) other entities exercising public

functions or providing public services under the control of an authority or

entity, falling within points (a) or (b); excluding authorities and entities when

acting in a judicial and legislative capacity;

(5) ‘public functions’ means functions of a regulatory, executive or administrative

nature, including but not limited to the preparation and adoption of regulatory

instruments and instruments of policy action, plans and programs,

implementing measures, decisions relating to authorisations and public

procurement;

(6) ‘tolerable level of residual risk' means the level of risk of climate-related

losses, that is expected to remain following the implementation of the measures

set out in the strategic plans referred to in Articles 6 and 7 that is regarded as

acceptable by the decision-maker at the time of adoption of the relevant plan,

taking into account uncertainties in the available evidence as well as financial,

technical and political constraints;

(7) ‘just resilience’ means ensuring that people in vulnerable situations and regions

and communities disproportionately impacted by climate risks are taken into

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account when developing and implementing policies and measures with

implications on climate resilience;

(8) ‘climate impact’ means the consequences of realised climate risks for natural

and human systems;

(9) ‘climate hazard’ means the potential occurrence of a climate-induced physical

event or trend or their physical impacts that may cause loss of life, injury, or

other health impacts, as well as damage and loss to property, infrastructure,

livelihoods, service provision, ecosystems and environmental resources; it

comprises slow-onset developments and rapidly developing climatic extremes

or increased variability;

(10) ‘tail risks’ means low-probability, high-impacts events occurring at the extreme

ends of a probability distribution;

(11) ‘tipping point’ means a critical threshold beyond which a system reorganises

often abruptly and/or irreversibly;

(12) ‘climate exposure’ means the presence of people; livelihoods; species or

ecosystems; environmental functions, services and resources; infrastructure; or

economic, social, or cultural assets in places and settings that could be

adversely affected by climate hazards;

(13) ‘climate vulnerability’ means the propensity or predisposition to be adversely

affected by the impacts of climate change, encompassing a variety of concepts

and elements, including sensitivity or susceptibility to harm and lack of

capacity to cope and adapt, including among groups in situations of

vulnerability;

(14) ‘cascading risks’ means a sequence of interconnected risks or hazards, where

the impact of one event amplifies or accelerates subsequent risks across

systems, policy areas, sectors or regions;

(15) ‘compounding risks’ means situations where multiple climate-related hazards,

vulnerabilities, or impacts interact in ways that amplify the overall risk, often

exceeding the sum of individual risks when considered in isolation.;

(16) ‘maladaptation’ means any measures that may lead to an increased risk of

adverse climate-related outcomes, including through increased greenhouse gas

emissions, increased or shifted vulnerability to climate change, more

inequitable outcomes, or diminished welfare, whether now or in the future;

(17) ‘European climate viewer’ means the digital web tool to be developed

converting the reference global warming trajectory referred to in Article 4 into

localised and decision relevant information on projected climate hazards.

Article 3

Climate resilience objective

The Union and each Member State shall continuously enhance the climate resilience of social,

economic and ecological systems to short-, medium- and long-term climate risks within the

Union, in particular with regard to risks to human life and health, to economy and

infrastructure and to nature and ecosystems, while safeguarding public security and food

security.

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Article 4

Reference global warming trajectory

1. The reference global warming trajectory for the short, medium and long-term is set

out in Annex I for the purposes of this Regulation.

2. Member States shall encourage public authorities to take into account the reference

global warming trajectory when exercising public functions with implications for

climate resilience, in particular in respect of budgeting, spatial planning, and

environmental impact assessments under Directive 2001/42/EC of the European

Parliament and of the Council15 and Directive 2011/92/EU of the European

Parliament and of the Council16.

Article 5

European and national climate risk assessments

1. The European Environment Agency shall carry out a European climate risk

assessment at Union-level by 30 June 2028 and every five years thereafter.

2. Each Member State shall carry out a national climate risk assessment, including at

subnational level, where applicable, by 30 June 2029 and every five years thereafter.

3. The climate risk assessments under this Article shall fulfil all of the following

requirements:

(a) they shall be based on at least the reference global warming trajectory set out in

Article 4;

(b) they shall include at least the elements set out in Annex II;

(c) they shall address at least the policy areas of Union-wide relevance for climate

resilience set out in Annex III;

(d) they shall be based on the best available knowledge;

(e) they shall consider relevant and science-based risk assessments, alternative

futures, extreme scenarios and low-probability high-impact climate risks;

(f) the national climate risk assessments referred to in paragraph 2 shall consider

at least the European climate risk assessment referred to in paragraph 1;

(g) their level of detail shall be proportionate to the relevance and significance of

the climate risks concerned.

4. The climate risk assessments pursuant to this Article shall be published after they

have been finalised. The disclosure of classified or security-sensitive information

may be withheld at Member States discretion.

5. Member States shall encourage public authorities to take into account the national

climate risk assessments and other relevant risk assessments when exercising public

functions with implications for climate resilience, in particular as regards of

15 Directive 2001/42/EC of the European Parliament and of the Council of 27 June 2001 on the

assessment of the effects of certain plans and programmes on the environment (OJ L 197, 21.7.2001,

pp. 30–37, ELI: http://data.europa.eu/eli/dir/2001/42/oj). 16 Directive 2011/92/EU of the European Parliament and of the Council of 13 December 2011 on the

assessment of the effects of certain public and private projects on the environment (OJ L 026,

28.1.2012, p. 1, ELI: http://data.europa.eu/eli/dir/2011/92/oj).

EN 21 EN

budgeting, spatial planning, and assessments under Directive 2001/42/EC and

Directive 2011/92/EU.

Article 6

Union strategic plan on climate resilience

1. The Commission shall adopt a Union strategic plan on climate resilience by 30

September 2028.

2. The Union strategic plan shall fulfil all of the following requirements:

(a) it shall be based on the European climate risk assessment referred to in Article

5(1) and other relevant risk assessments;

(b) it shall be based on at least the reference global warming trajectory set out in

Article 4;

(c) it shall aim to ensure that the residual risks from the major climate risks

referred to in point 1 of Annex II are tolerable;

(d) it shall address at least the policy areas of Union-wide relevance for climate

resilience set out in Annex III;

(e) it shall include at least the elements set out in points 1 to 3, 7 to 9 and 12 to 14

of Annex IV;

(f) it shall fulfil the requirements for adopting a Union strategy on adaptation to

climate change set out in Article 5(2) of Regulation (EU) 2021/1119;

(g) it shall promote nature-based solutions and ecosystem-based climate

adaptation;

(h) it shall take into consideration people in vulnerable situations as well as

communities disproportionately impacted by climate risks in order to promote

just resilience;

(i) it shall take into consideration regions and territories disproportionately

impacted by climate risks throughout the plan.

3. The public shall be given an opportunity to participate in the preparation of the

Union strategic plan. The feedback received from the public shall be taken into

account when finalising the plan. The plan shall be published after it has been

adopted.

4. The Commission shall incorporate the Union-level indicators set out in Annex V into

the Union strategic plan.

5. The Commission shall evaluate and update the Union strategic plan by 30 September

2033 and every five years thereafter, taking into account the assessment of the

previous Union strategic plan.

Article 7

National strategic plan on climate resilience

1. Each Member State shall adopt a national strategic plan on climate resilience by 31

December 2030.

2. The national strategic plan shall fulfil all of the following requirements:

EN 22 EN

(a) it shall be based on climate risk assessments pursuant to Article 5 and other

relevant risk assessments;

(b) it shall be based on at least the reference global warming trajectory set out in

Article 4;

(c) it shall aim to ensure that the residual risks from the major climate risks

referred to in point 1 of Annex II are tolerable;

(d) it shall aim to ensure consistency with the Union strategic plan pursuant to

Article 6;

(e) it shall address at least the policy areas of Union-wide relevance for climate

resilience set out in Annex III;

(f) it shall include at least the elements set out in Annex IV, excluding point 9

thereof;

(g) it shall fulfil the requirements for adopting national adaptation strategies and

plans set out in Article 5(4) of Regulation (EU) 2021/1119;

(h) it shall promote nature-based solutions and ecosystem-based climate

adaptation;

(i) it shall take into consideration people in vulnerable situations as well as

communities disproportionately impacted by climate risks in order to promote

just resilience;

(j) it shall take into consideration regions and territories disproportionately

impacted by climate risks throughout the plan.

3. Member States may, for the purposes of complying with points 11, 13 and 14 of

Annex IV, indicate planned or existing measures to address climate resilience under

sectoral legislation that fulfil the content requirements for the national strategic

plans. In such cases, Member States shall indicate in the national strategic plan where

those measures fully meet the requirements of this Regulation.

4. Each Member State shall designate a central coordinating authority with sufficient

administrative competence to oversee the preparation and implementation of the

national strategic plan.

5. Subnational public authorities and the public shall be given early and effective

opportunities to participate in the preparation of the national strategic plan.

Moreover, such opportunities shall be inclusive and accessible. The feedback

received from the subnational public authorities and the public and opinions

expressed by other Member States pursuant to Article 8 shall be taken into account

when preparing the plan. The national strategic plan shall be published after it has

been adopted. The disclosure of classified or security-sensitive information may be

withheld at Member States discretion.

6. Each Member State shall identify, for each major climate risk referred to in point 1

of Annex II, one or more public authorities responsible for managing that climate

risk.

7. Each Member State shall pursue the implementation of the measures set out in the

national strategic plan, while taking into account changing risks, new evidence,

unforeseen costs and available financial resources. The implementation of the plan

EN 23 EN

under this Article shall not impede or delay time-critical activities essential to

national security, defence readiness or military preparedness.

8. Each Member State shall evaluate and update the national strategic plan every five

years.

Article 8

Transboundary cooperation

1. When preparing or updating the national strategic plan pursuant to Article 7, each

Member State shall consult the Member States likely to be significantly impacted by

the plan, including at least its neighbouring Member States.

2. The consultations referred to in paragraph 1 shall address at least potential

transboundary risks, planned measures and the possibilities for transboundary

cooperation on climate resilience. Consultations should, where appropriate, be

carried out through existing cooperation frameworks and mechanisms, where these

provide a basis for addressing the relevant climate risks.

3. Where a transboundary consultation is undertaken in accordance with Article 7 of

Directive 2001/42/EC, such consultation shall be deemed to satisfy the obligations

laid down in this Article, provided that the requirements of paragraphs 1 and 2 are

complied with.

Article 9

Online platform on climate resilience knowledge

1. The Commission shall ensure that an online platform is available to facilitate the

implementation of this Regulation and to provide access to information on climate

resilience, climate adaptation and climate risks, including access to the European

climate viewer.

2. The Commission shall ensure coordination with existing Union knowledge

platforms, services and relevant research networks, ensuring interoperability,

avoiding duplication and safeguarding security-sensitive information.

Article 10

Statistics on loss of life and economic losses attributable to climate change

1. By 31 December 2030 and annually thereafter, the Commission (Eurostat) shall

disseminate statistics on loss of life and economic losses attributable to climate

change, compiled from data provided by Member States and, if appropriate, from

other relevant data sources.

2. The Commission is empowered to adopt delegated acts in accordance with Article 13

in order to establish the data regarding climate-related mortality and the data on

economic losses attributable to climate change to be provided by Member States.

Article 11

Role of the European Environment Agency

EN 24 EN

The European Environment Agency, established under Regulation (EC) No 401/2009 of the

European Parliament and of the Council17, shall act as a centre of excellence on climate

resilience and climate adaptation and assist the Commission and the Member States for the

purposes of their work to comply with Articles 3, 4 and 5 to 9 in accordance with its annual

work programme. That assistance shall include, as required:

(a) knowledge development and capacity-building at Union and national level for

climate risk assessments and climate resilience planning, including Union-level

indicators on climate resilience;

(b) compilation and analysis of information from Member States on climate

resilience policies and measures, including the maintenance and update of a

database on those policies and measures within the online platform referred to

in Article 9and knowledge development to support assessments of progress;

(c) support for the online platform on climate resilience knowledge referred to in

Article 9.

Article 12

Amendment of Annexes

1. The Commission is empowered to adopt delegated acts in accordance with Article 13

to amend Annex I by updating the reference global warming trajectory referred to in

Article 4 in order to align it with the most recent scientific knowledge. The update of

the trajectory shall be based on the best available and most recent scientific evidence,

taking into account advice from the European Scientific Advisory Board on Climate

Change (ESABCC), established under Article 10a of Regulation (EC) No 401/2009.

2. The Commission is empowered to adopt delegated acts in accordance with Article 13

to amend Annex II to align it with new evidence regarding best practices for

assessing climate risks, by adding or removing elements to be taken into account in

the climate risk assessments under Article 5. Such amendments shall be based on the

findings of the European climate risk assessments under Article 5(1).

3. The Commission is empowered to adopt delegated acts in accordance with Article 13

so as to amend Annex III, by adding or removing policy areas to be addressed in the

climate risk assessments under Article 5 and in the Union and national strategic plans

pursuant to Articles 6 and 7, in order to align it with new evidence regarding policy

areas of Union-wide relevance for climate resilience. Such amendments shall be

based on the findings of the European climate risk assessments under Article 5(1).

4. The Commission is empowered to adopt delegated acts in accordance with Article 13

to amend point 12, of Annex IV by adapting the requirements for the climate

resilience objectives and targets to be included, where relevant, in the strategic plans

pursuant to Articles 6 and 7 in order to reflect future evidence on worsening climate

impacts.

5. The Commission is empowered to adopt delegated acts in accordance with Article 13

to amend Annex V in order to adapt the Union-level indicators to the best available

and most recent scientific knowledge, taking into account relevant scientific,

technical and methodological developments at international level.

17 Regulation (EC) No 401/2009 of the European Parliament and of the Council of 23 April 2009 on the

European Environment Agency and the European Environment Information and Observation Network

(Codified version) (OJ L 126, 21.5.2009, p. 13, ELI: http://data.europa.eu/eli/reg/2009/401/oj).

EN 25 EN

Article 13

Exercise of the delegation

1. The power to adopt delegated acts is conferred on the Commission subject to the

conditions laid down in this Article.

2. The power to adopt delegated acts referred to in Articles 11(5) and 12(1) to (5) shall

be conferred on the Commission for an indeterminate period of time from [the date

of entry into force of this Regulation]. The Commission shall draw up a report on the

delegation of power not later than nine months before the end of the five-year period.

The delegation of power shall be tacitly extended for periods of an identical duration

unless the European Parliament or the Council objects to such extension not later

than three months before the end of each period.

3. The delegation of power referred to in Articles 11(5) and 12(1) to (5) may be

revoked at any time by the European Parliament or by the Council. A decision to

revoke shall put an end to the delegation of the power specified in that decision. It

shall take effect the day following the publication of the decision in the Official

Journal of the European Union or at a later date specified therein. It shall not affect

the validity of any delegated acts already in force.

4. Before adopting a delegated act, the Commission shall consult experts designated by

each Member State in accordance with the principles laid down in the

Interinstitutional Agreement of 13 April 2016 on Better Law-Making.

5. As soon as it adopts a delegated act, the Commission shall notify it simultaneously to

the European Parliament and to the Council.

6. Delegated acts adopted pursuant to Articles 11(5) and 12(1) to (5) shall enter into

force only if no objection has been expressed either by the European Parliament or

by the Council within a period of two months of notification of that act to the

European Parliament and the Council or if, before the expiry of that period, the

European Parliament and the Council have both informed the Commission that they

will not object. That period shall be extended by two months at the initiative of the

European Parliament or of the Council.

Article 14

Amendments to Regulation (EU) 2018/1999

Regulation (EU) 2018/1999 is amended as follows:

(1) in Article 4, point (a)(1)(iii) is replaced by the following:

‘(iii) where applicable to meet the objectives and targets of the Energy Union and the

long-term Union greenhouse gas emissions commitments consistent with the Paris

Agreement, other objectives and targets, including sector targets.’;

(2) in Article 17, paragraph 2 point (d) is deleted;

(3) the heading of Article 19 is replaced by the following: ‘Integrated reporting on

national climate resilience policies and measures, financial and technology support

provided to developing countries and auctioning revenues’;

(4) in Article 19, paragraph 1 is replaced by the following:

‘By 15 March 2029, and every two years thereafter, Member States shall report to

the Commission information on the implementation of national climate resilience

EN 26 EN

policies and measures, including the information specified in Part 1 of Annex VIII

and in accordance with the reporting requirements agreed upon under the UNFCCC

and the Paris Agreement.’;

(5) in Article 42, point (e) is replaced by the following:

'(e) disseminating information collected under this Regulation, including maintaining

and updating a database on Member States' mitigation policies and measures’;

(6) in Article 42, the following point (f) is added:

‘(f) quality assurance, quality control and dissemination of information on national

climate resilience policies and measures reported under Article 19’;

(7) in Annex I, Part 1, Section A, point (2.1.1) (ii) is replaced by the following:

‘(ii) Where applicable, other national objectives and targets consistent with the Paris

Agreement and the existing long-term strategies. Where applicable for the

contribution to the overall Union commitment of reducing the GHG emissions, other

objectives and targets, including sector targets, if available.';

(8) in Annex IV, point (2.1.3) is deleted;

(9) the heading of Annex VIII is replaced by the following: ‘INFORMATION ON THE

IMPLEMENTATION OF NATIONAL CLIMATE RESILIENCE POLICIES AND

MEASURES, FINANCIAL AND TECHNOLOGY SUPPORT PROVIDED TO

DEVELOPING COUNTRIES AND AUCTIONING REVENUES’;

(10) in Annex VIII, Part 1 is replaced by the following:

‘Part 1

Reporting on national climate resilience policies and measures

Information to be included in the reports referred to in Article 19(1):

(a) national climate risk assessments pursuant to Article 5(2) of Regulation (EU)

2027 /… [European Climate Resilience Law], including the key climate hazards and

major climate risks identified, including transboundary relevance;

(b) application of the reference global warming trajectory referred to in Article 4 of

Regulation (EU) 2027 /… [European Climate Resilience Law] in the national climate

risk assessments and the national strategic plans referred to in Article 7 of Regulation

(EU) 2027 /… [European Climate Resilience Law];

(c) implementation of the national strategic plans referred to in Article 7 of

Regulation (EU) 2027/… [European Climate Resilience Law], including national

objectives and targets, indicators and the tolerability of residual risk from major

climate risks identified in the national climate risk assessments;

(d) other national policies and national legislation relevant to climate resilience;

(e) overview of implemented and planned climate resilience measures by policy area

of Union-wide relevance for climate resilience set out in Annex III to Regulation

(EU) 2027 /… [European Climate Resilience Law], including competent authorities

or other entities referred to in point 12(a) of Annex IV to Regulation (EU) 2027/…

[European Climate Resilience Law];

(f) overview of outcomes of national progress assessments, policy cycle evaluations

and their use in subsequent policy revisions;

EN 27 EN

(g) progress in achieving national objectives and targets and climate resilience

measures set out in the plans;

(h) Union-level indicators set out in Annex V to Regulation (EU) 2027 /…

[European Climate Resilience Law], in particular on loss of life and economic losses

attributable to climate change;

(i) good practices, including climate resilience solutions.’.

Article 15

Review and reporting

By 30 September 2033, the Commission shall present a report to the European Parliament and

to the Council on the application of this Regulation. The report shall be accompanied, where

appropriate, by a legislative proposal.

Article 16

Entry into force

This Regulation shall enter into force on the twentieth day following that of its publication in

the Official Journal of the European Union.

This Regulation shall be binding in its entirety and directly applicable in all Member States.

Done at Brussels,

For the European Parliament For the Council

The President The President

EN 1 EN

LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT

Contents

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE ................................................. 3

1.1. Title of the proposal/initiative ...................................................................................... 3

1.2. Policy area(s) concerned .............................................................................................. 3

1.3. Objective(s) .................................................................................................................. 3

1.3.1. General objective(s) ..................................................................................................... 3

1.3.2. Specific objective(s) ..................................................................................................... 3

1.3.3. Expected result(s) and impact ...................................................................................... 3

1.3.4. Indicators of performance ............................................................................................ 3

1.4. The proposal/initiative relates to: ................................................................................. 4

1.5. Grounds for the proposal/initiative .............................................................................. 4

1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for

roll-out of the implementation of the initiative ............................................................ 4

1.5.2. Added value of EU involvement (it may result from different factors, e.g.

coordination gains, legal certainty, greater effectiveness or complementarities). For

the purposes of this section 'added value of EU involvement' is the value resulting

from EU action, that is additional to the value that would have been otherwise

created by Member States alone. ................................................................................. 4

1.5.3. Lessons learned from similar experiences in the past .................................................. 5

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments ....................................................................................... 6

1.5.5. Assessment of the different available financing options, including scope for

redeployment ................................................................................................................ 6

1.7. Method(s) of budget implementation planned ............................................................. 7

2. MANAGEMENT MEASURES................................................................................... 9

2.1. Monitoring and reporting rules .................................................................................... 9

2.2. Management and control system(s) ............................................................................. 9

2.2.1. Justification of the budget implementation method(s), the funding implementation

mechanism(s), the payment modalities and the control strategy proposed .................. 9

2.2.2. Information concerning the risks identified and the internal control system(s) set up

to mitigate them............................................................................................................ 9

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between

the control costs and the value of the related funds managed), and assessment of the

expected levels of risk of error (at payment & at closure) ........................................... 9

2.3. Measures to prevent fraud and irregularities ................................................................ 9

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE ............ 10

EN 2 EN

3.1. Heading(s) of the multiannual financial framework and expenditure budget line(s)

affected ....................................................................................................................... 10

3.2. Estimated financial impact of the proposal on appropriations ................................... 11

3.2.1. Summary of estimated impact on operational appropriations.................................... 11

3.2.1.1. Appropriations from voted budget ............................................................................. 11

3.2.2. Estimated output funded from operational appropriations (not to be completed for

decentralised agencies)............................................................................................... 15

3.2.3. Summary of estimated impact on administrative appropriations ............................... 17

3.2.3.1. Appropriations from voted budget .............................................................................. 17

3.2.4. Estimated requirements of human resources.............................................................. 17

3.2.4.1. Financed from voted budget....................................................................................... 18

3.2.5. Overview of estimated impact on digital technology-related investments ................ 20

3.2.6. Compatibility with the current multiannual financial framework.............................. 21

3.2.7. Third-party contributions ........................................................................................... 21

3.2.8. Estimated human resources and the use of appropriations required in the European

Environment Agency ................................................................................................. 22

3.2.9. Estimated human resources and the use of appropriations required in the EIOPA ... 24

3.3. Estimated impact on revenue ..................................................................................... 27

4. DIGITAL DIMENSIONS .......................................................................................... 28

4.1. Requirements of digital relevance .............................................................................. 28

4.2. Data ............................................................................................................................ 30

4.3. Digital solutions ......................................................................................................... 33

4.4. Interoperability assessment ........................................................................................ 33

4.5. Measures to support digital implementation .............................................................. 34

EN 3 EN

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE

1.1. Title of the proposal/initiative

Proposal for a Regulation of the European Parliament and of the Council establishing

a framework to enhance climate resilience and amending Regulation (EU)

2018/1999, (European Climate Resilience Law).

1.2. Policy area(s) concerned

Climate Action

1.3. Objective(s)

1.3.1. General objective(s)

The overall objective is to establish a framework to enhance climate resilience across

the Union and to contribute to the global adaptation goal set in Article 7 of the Paris

Agreement and the objectives on adaptation to climate change set in the European

Climate Law (Regulation (EU) 2021/1119 of the European Parliament and of the

Council).

1.3.2. Specific objective(s)

The specific objective is to enhance, indirectly through changes to the policy

framework, the climate resilience of social, economic and ecological systems against

short-, medium- and long-term climate risks within the Union, in particular with

regard to risks to human life and health, to economy and infrastructure, and to nature

and ecosystems.

1.3.3. Expected result(s) and impact

Specify the effects which the proposal/initiative should have on the beneficiaries/groups targeted.

The framework established by the Regulation is expected to:

- Provide clarity on the responsibilities for managing climate risks across all policy

areas through the integration of climate resilience considerations into risk

assessments, policy design and planning in the Union and the Member States, using a

common reference global warming trajectory;

- Ensure a consistent assessment of climate risks and vulnerabilities to climate

change in the Union and the Member States;

- Ensure across all policy sectors the implementation of actions and measures,

designed to address major climate risks and to achieve the climate resilience

objective; and to

- Stimulate cooperation between Member States to address transboundary risks.

The initiative will benefit society as a whole, including all economic sectors, through

enhanced and better coordinated climate preparedness and disaster risk management.

Better climate preparedness will help sustain job and income opportunities and have

positive effects on citizen’s health, nature and biodiversity, natural and cultural

heritage and identity, as well as quality and security of food and water.

1.3.4. Indicators of performance

Specify the indicators for monitoring progress and achievements.

EN 4 EN

The Commission is to monitor progress in implementing the Regulation as part of

existing processes and evaluation.

1.4. The proposal/initiative relates to:

☑ a new action

a new action following a pilot project / preparatory action1

the extension of an existing action

a merger or redirection of one or more actions towards another/a new action

1.5. Grounds for the proposal/initiative

1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for

roll-out of the implementation of the initiative

The Commission puts forward this framework with a clear vision and decisive action

to close the Union’s climate preparedness and resilience gap. This framework builds

upon the existing European Climate Law, which requires ensuring continuous

progress in enhancing adaptive capacity, strengthening resilience and reducing

vulnerability to climate change in accordance with Article 7 of the Paris Agreement.

The proposed regulation will be directly applicable from the day of its entry into

force.

However, a series of administrative tasks will need to be deployed as soon as

possible, some of them starting already in 2026 (i.e. during the ordinary legislative

procedure, ahead of the adoption by the European Parliament and the Council) and

some after entry into force. While some tasks will be for a limited term (e.g. the

creation of online tools) others will be longer term and recurrent for as long as the

Regulation applies. The needs before entry into force will be covered from existing

resources; the LFDS addresses needs from the 2028. In case of earlier entry into

force, temporary measures under the current MFF may need to be foreseen.

The Framework will create an iterative climate resilience cycle between the Union

and Member State level and, to the extent possible, with other EU and international

processes (e.g. MFF, Governance Regulation, UCPM Regulation).

1.5.2. Added value of EU involvement (it may result from different factors, e.g.

coordination gains, legal certainty, greater effectiveness or complementarities). For

the purposes of this section 'added value of EU involvement' is the value resulting

from EU action, that is additional to the value that would have been otherwise

created by Member States alone.

Reasons for action at EU level (ex ante): Climate hazards increasingly affect the

entire EU territory and put core policy areas at risk, thus demanding strong EU-level

action. Climate impacts can undermine the effective delivery of EU policies

including the functioning of the single market, as well as the Union’s ability to

uphold its fundamental rights and pursue its international obligations and promote

more ambitious approaches internationally. Actions at the national level would not

be sufficient in addressing climate risks. Policy intervention at the EU-level – in

concert with national, regional and local action - is necessary to effectively and

1 As referred to in Article 58(2), point (a) or (b) of the Financial Regulation.

EN 5 EN

efficiently achieve the needed levels of systemic, EU-wide climate resilience and

preparedness.

Many climate risks are shared between MS and span national borders. Impacts can

cascade and compound at broader economic and societal level degrading Union-wide

cohesion, financial stability and investment outlook, posing a wider systemic threat

with considerable potential to impact on the free movement of goods, services,

capital and persons between countries. Current policies are not keeping pace with the

increasing impacts. To be efficient and effective, climate resilience policies require

more uniform application, and coordinated action across different sectors and

governance levels. Links between risks and policies have to be strengthened to avoid

compromising the prosperity and safety of all EU citizens and industry.

Expected generated EU added value (ex post): This initiative is expected to

generate added value over and above what the Member States can achieve nationally

for the following reasons:

- The magnitude and complexity of the challenge, and the fact that climate change

affects many policy areas of shared competence, requires an all-of-government

approach that includes intervention at the EU policy level.

- Complementing different national policies and rules, EU-level action is needed for

promoting a more harmonised and coherent understanding and approach to climate

resilience at national and subnational level and across policy areas, thereby

effectively reducing transnational, cross-border and systemic risks.

- In addition to contributing to greater effectiveness, EU-level intervention for

climate resilience has significant potential for achieving policy objectives in a more

cost-efficient manner. For instance, a single EU-wide early warning and surveillance

system for wildfires or climate-sensitive infectious diseases would be more cost

effective and could deliver better results in addressing cross-border and

transboundary impacts than the development and operation of separate systems by

each Member State, thereby contributing to strengthened overall preparedness

through an enhanced climate resilience framework.

- Similarly, improving the functioning of the internal market for climate resilience

products and services (e.g. heat-protection gear for workers, less water intensive and

more climate resilient crops, smart building cooling solutions) holds potential for

economies of scale, greater competitiveness at the global scale, and better leverage

over global norms and regulatory standards.

- Strengthening the role of climate resilience in EU budgetary and economic

governance frameworks not only provides a common direction to public authorities,

but also - by extension - to the private sector and citizens.

- EU-led policies and support measures for climate resilience have a bigger chance of

leading to true transformation. These will not only make the EU and the Member

States more prepared to face current and future climate risks, but also strengthen core

values of the Union, such as solidarity, cohesion and reduction of inequalities.

1.5.3. Lessons learned from similar experiences in the past

For this initiative, the Commission has endeavoured to utilise past experiences to

inform the content of the intiative. The Commission conducted a call for evidence

and open public consultation to enable different stakeholders to share their

EN 6 EN

perspective, and also collected feedback through Commission expert groups, such as

the Reflection Group on Mobilising Climate Resilience Financing and the Industrial

Forum.

Various reports underpin the analysis. The 2024 EUCRA report provided useful

information for Commission initiatives on climate adaptation and informed Member

States on their national processes. To increase complementarity between national and

other EU-level risk assessments, the scoping process of the next EUCRA should be

defined in close coordination with the policy risk owners. The first EUCRA provided

quantitative inputs for the initiative, synthesising current data on climate risks in the

EU. Commission reports, such as Assessment of EU and Member States adaptation

needs or Assessing the Macro-Fiscal Risks from Climate Change also provided

qualitative and quantitative data.

Besides the consultations and these reports, the Commission used data and

knowledge available in published reports authored and reviewed by experts in the

field of climate change, climate risks, and resilience, such as the IPCC, ESABCC and

the EEA. Furthermore, they relied on academic research from the Commission,

notably the JRC, Copernicus and other academic sources outside of the Union

institutions.

Alongside other academic papers and policy reports, they formed the scientific basis

of the Impact Assessment, through giving an overview of the current state of climate

change and potential future risks in Europe, hence providing the foundation for the

policy options given in the report.

Decision-relevant evidence was also collected drawing from real-life experiences and

discussions amongst regional and local authorities (as well as other stakeholders) and

Horizon Europe projects within the EU Mission on Adaptation to Climate Change.

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments

The proposal is fully in line with the objectives of the Commission’s proposal for the

multiannual financial framework (MFF) 2028–2034. Protecting people and building

preparedness and resilience is one of the cross-cutting priorities under the new MFF.

The implementation of the new regulation proposal will have financial implications

for the Commission, which would be covered by the EU budget under the MFF

2028-2034. Depending on the outcome of the ongoing negotiations on the

Commission’s proposal for the next MFF, the spending presented in this financial

legislative statement will be undertaken under Heading 2 (Competitiveness,

Prosperity and Security, predominantly from the European Competitiveness Fund)

and Heading 4 (Administration) of the MFF. In addition, Member States shall

include actions supporting climate resilience in the National and Regional

Partnership Plans supported by Heading 1 of the MFF.

1.5.5. Assessment of the different available financing options, including scope for

redeployment

Successful delivery and proper implementation of the Regulation entail new tasks

and activities for the Commission, the EEA and European Insurance and

Occupational Pensions Authority (EIOPA). This will require human resources and

procurement resources for external contractors.

EN 7 EN

To ensure the achievement of the objectives, limited additional resources are needed,

while most of the needs in DG CLIMA and EEA will be met by redeployment of

existing resources. The possible alternatives would be continued reliance on ad hoc

solutions through non-permanent staffing and task-based outsourcing and contracts,

but this would not ensure continuity, independence of implementation or knowledge

retention; it may create dependencies for fulfilling core obligations under the

Regulation. Overall, the increases for the resources to the EEA are replacing current

financing under Service Level Agreements (SLA) for tasks that will become

permanent. This is in line with the call of the European Parliament as part of the

2024 budgetary discharge procedure that Commission should ensure that agencies

are adequately staffed to perform permanent tasks with in-house staff. The

Commission does not have direct competences to manage such tasks in-house; the

alternative of outsourcing to other organisations would be unlikely to deliver on the

objectives, given that EEA and EIOPA are respectively uniquely placed in terms of

institutional roles to ensure delivery of the identified tasks.

The appropriations required for additional human resources in the Commission will

be met by any additional allocation which may be granted to the managing DG under

the annual allocation procedure and in the light of budgetary constraints. DG CLIMA

will address a reasoned request to the Corporate Management Board seeking the

redeployment of staff from the limited redeployment pool of the Commission.

With regards to financing, the needs will be met through allocation of resources

within the next MFF. The estimated impact on expenditure and staffing for 2028 and

beyond is added for illustrative purposes only and does not pre-judge the next

multiannual financial framework. The source of financing and scope of Union

financial commitment in the post-2027 period remain subject to the outcome of

interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be

determined through the annual budgetary procedure. All appropriations and staffing

allocations as of 2028 are indicative.

The start-up period in 2026-2027 will be financed from internal resources.

1.6. Duration of the proposal/initiative and of its financial impact

limited duration

–  in effect from [DD/MM]YYYY to [DD/MM]YYYY

–  financial impact from YYYY to YYYY for commitment appropriations and

from YYYY to YYYY for payment appropriations.

unlimited duration

– Implementation with a start-up period from 2026 to 2027,

– followed by full-scale operation.

1.7. Method(s) of budget implementation planned

Direct management by the Commission

–  by its departments, including by its staff in the Union delegations;

–  by the executive agencies

Shared management with the Member States

Indirect management by entrusting budget implementation tasks to:

EN 8 EN

–  third countries or the bodies they have designated

–  international organisations and their agencies (to be specified)

–  the European Investment Bank and the European Investment Fund

–  bodies referred to in Articles 70 and 71 of the Financial Regulation

–  public law bodies

–  bodies governed by private law with a public service mission to the extent that

they are provided with adequate financial guarantees

–  bodies governed by the private law of a Member State that are entrusted with

the implementation of a public-private partnership and that are provided with

adequate financial guarantees

–  bodies or persons entrusted with the implementation of specific actions in the

common foreign and security policy pursuant to Title V of the Treaty on

European Union, and identified in the relevant basic act

– bodies established in a Member State, governed by the private law of a

Member State or Union law and eligible to be entrusted, in accordance with

sector-specific rules, with the implementation of Union funds or budgetary

guarantees, to the extent that such bodies are controlled by public law bodies or

by bodies governed by private law with a public service mission, and are provided

with adequate financial guarantees in the form of joint and several liability by the

controlling bodies or equivalent financial guarantees and which may be, for each

action, limited to the maximum amount of the Union support.

Comments

The Commission will be supported by the EEA in accordance with its annual work

programme by supporting knowledge development, capacity-building and technical dialogue

at Union and national level, strengthening climate risk assessments, sectoral analyses and

assessments, the development of climate resilience indicators, supporting data collection,

analysis and reporting updating a database on Member States’ national climate resilience and

adaptation policies and measures and contributing to a European online platform on climate

resilience knowledge. It will also be supported by the EIOPA in managing the Observatory

for Catastrophe Risk Insurability.

EN 9 EN

2. MANAGEMENT MEASURES

2.1. Monitoring and reporting rules

The Commission shall prepare a report on the operation of this Regulation by 30

September 2033 at the latest. This shall be submitted to the European Parliament and

to the Council, and followed, where appropriate, by legislative proposals to revise

this Regulation.

The proposal uses and streamlines existing regular national and EU level processes

to monitor progress and implementation of the proposal.

2.2. Management and control system(s)

2.2.1. Justification of the budget implementation method(s), the funding implementation

mechanism(s), the payment modalities and the control strategy proposed

The initiative involves procurement and impact on the COM HR. Standard rules for

this type of expenditure apply. As regards the control strategy for additional

expenditure in the agencies, EU Decentralised Agencies apply a financial framework

modelled on the Commission’s own Financial Regulation. They work closely with

the Commission’s Internal Audit Service to ensure that appropriate standards are met

in all areas of internal control framework.

2.2.2. Information concerning the risks identified and the internal control system(s) set up

to mitigate them

N/A – cf. above.

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between

the control costs and the value of the related funds managed), and assessment of the

expected levels of risk of error (at payment & at closure)

N/A – cf. above.

2.3. Measures to prevent fraud and irregularities

N/A – cf. above.

EN 10 EN

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE

The estimated impact on expenditure and staffing for 2028 and beyond is added for

illustrative purposes only and does not pre-judge the next multiannual financial

framework. The source of financing and scope of Union financial commitment in the

post-2027 period remain subject to the outcome of interinstitutional negotiations on

the MFF 2028-2034 and thereafter shall be determined through the annual budgetary

procedure. All appropriations and staffing allocations as of 2028 are indicative.

3.1. Heading(s) of the multiannual financial framework and expenditure budget

line(s) affected

• Existing budget lines (or budget lines already planned for as per MFF proposal)

In order of multiannual financial framework headings and budget lines.

Heading of

multiannual

financial

framework

Budget line Type of

expenditure Contribution

Number

Diff./Non-

diff.1

from

EFTA

countries2

from

candidate

countries

and

potential

candidates3

From

other

third

countries

other assigned

revenue

2

Successor budget line of 03.10.03 -

European Insurance and Occupational

Pensions Authority Diff. YES NO NO YES

2

Successor budget line of 09.10.02 -

European Environment Agency

Diff. YES YES YES NO

2 [XX.YY.YY.YY] – ECF Clean Transition

Window Diff. TBD TBD TBD TBD

4 Successor budget line of 20 01 02 01 -

Headquarters and Representation offices Non diff. NO NO NO NO

4

Successor budget line of 20 02 01 01 -

Contract staff

Non diff. NO NO NO NO

4 Successor budget line of 20 02 06 01 -

Mission and representation expenses Non diff. NO NO NO NO

4 Successor budget line of 20 02 06 02 -

Conference and meeting costs Non diff. NO NO NO NO

1 Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. 2 EFTA: European Free Trade Association. 3 Candidate countries and, where applicable, potential candidates from the Western Balkans.

EN 11 EN

3.2. Estimated financial impact of the proposal on appropriations1

3.2.1. Summary of estimated impact on operational appropriations

–  The proposal/initiative does not require the use of operational appropriations

–  The proposal/initiative requires the use of operational appropriations, as explained below

3.2.1.1. Appropriations from voted budget

EUR million (to three decimal places)

Heading of multiannual financial framework 2 Competitiveness, Prosperity and Security

DGs: CLIMA, DEFIS Year Year Year Year Year Year Year

TOTAL MFF 2028-2034 2028 2029 2030 2031 2032 2033 2034

Operational appropriations

Budget line (ECF CT window) Commitments (1a) 0 0 0 0 0 0 0 0

Payments (2a) 0 0 0 0 0 0 0 0

Budget line Commitments (1b) 0

Payments (2b) 0

Appropriations of an administrative nature financed from the envelope of specific programmes2

Budget line (3) 0

TOTAL appropriations Commitments =1a+1b+3 0 0 0 0 0 0 0 0

1 These redeployment efforts – while fully respecting the stable staffing principle – will likely require deprioritisation of tasks within the Commission services. The

Commission will revisit the needs and the scope for redeployment within the indicated number of staff, following an agreement on the next MFF. 2 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research.

EN 12 EN

for DG CLIMA, DEFIS Payments =2a+2b+3 0 0 0 0 0 0 0 0

Resources will be needed to support various implementation tasks related to the legislative provisions that will be managed by the Commission

(notably DG CLIMA and DEFIS, implementation includes at least FISMA, JRC). The procured activities include support contracts for the

implementation of the Regulation, development of guidance documents and tools for implementing the regulation by the Commission and

Member States, supporting resilience technologies and catastrophe risk insurability, and impact assessment support contracts. This includes

administrative arrangement(s) with JRC, in particular for support to the EUCRA and for monitoring and indicators. Notably, it does not include

the costing for the contributions from the Copernicus Climate Change services or Destination Earth.

EEA and EIOPA Year Year Year Year Year Year Year TOTAL

2028 - 2034 2028 2029 2030 2031 2032 2033 2034

Successor budget line of 03.10.03 - EU

Budget contribution to the EEA 0 0 0 0 0 0 0 0

Successor budget line of 03.10.03 - EU

Budget contribution to EIOPA 0 0 0 0 0 0 0 0

total 0 0 0 0 0 0 0 0

Resources will be needed to support various implementation tasks related to the legislative provisions that will be managed by the EEA, notably

preparation of the EUCRA, development and maintenance of existing and new tools and support to Member States. Resources will be needed for

ad hoc financing solutions for the Climate-ADAPT digital platform, the EUCRA and local and regional support under the 2021-2027 MFF.

Resources will be needed to bring functions relating to EUCRA into the EEA that, in the current SLA, are externalised to contractors. Fee-

financing has been considered, in particular for support provided to Member States, however in our assessment, this would create a de facto

situation where many Member States would not have access to such support. It is in the Union’s interest that all Member States manage their

climate risks.

EIOPA will need to establish and manage the Observatory for Catastrophe Risk Insurability, a specific and new deliverable that will require

dedicated resources not available under its current allocations for the fulfilment of established mandates.

EN 13 EN

Year Year Year Year Year Year Year TOTAL

MFF 2028-

2034 2028 2029 2030 2031 2032 2033 2034

TOTAL

operational

appropriations

(including

contribution to

decentralised

agency)

Commitments (4) 0 0 0 0 0 0 0 0

Payments (5) 0 0 0 0 0 0 0 0

TOTAL appropriations of an

administrative nature financed from

the envelope for specific

programmes

(6) 0 0 0 0 0 0 0 0

TOTAL

appropriations

under

HEADING 2

Commitments =4+6 0 0 0 0 0 0 0 0

of the

multiannual

financial

framework

Payments =5+6 0 0 0 0 0 0 0 0

Year Year Year Year Year Year Year TOTAL MFF

2028-2034 2028 2029 2030 2031 2032 2033 2034

• TOTAL

operational

appropriations

(all operational

headings)

Commitments (4) 0 0 0 0 0 0 0 0

Payments (5) 0 0 0 0 0 0 0 0

• TOTAL appropriations of an

administrative nature financed (6) 0 0 0 0 0 0 0 0

EN 14 EN

from the envelope for specific

programmes (all operational

headings)

TOTAL

appropriations

Under

Heading 1 to 3

Commitments =4+6 0 0 0 0 0 0 0 0

of the multiannual

financial

framework Payments =5+6 0 0 0 0 0 0 0 0

(Reference

amount)

Heading of multiannual financial

framework 4 Administration

DG: CLIMA Year Year Year Year Year Year Year TOTAL

MFF

2028-

2034 2028 2029 2030 2031 2032 2033 2034

 Human resources 0 0 0 0 0 0 0 0

 Other administrative expenditure 0 0 0 0 0 0 0 0

TOTAL

DG

CLIMA 0 0 0 0 0 0 0 0

TOTAL appropriations

under HEADING 4 of

the multiannual financial

framework

(Total commitments = Total payments) 0 0 0 0 0 0 0 0

EN 15 EN

EUR million (to three decimal places)

For justifications, please see the explanation after tables in section 3.2.4.1.

Year Year Year Year Year Year Year TOTAL

MFF 2028-

2034 2028 2029 2030 2031 2032 2033 2034

TOTAL

appropriations

under

HEADINGS

1-4

Commitments =4+6 0 0 0 0 0 0 0 0

of the

multiannual

financial

framework

Payments =5+6 0 0 0 0 0 0 0 0

3.2.2. Estimated output funded from operational appropriations (not to be completed for decentralised agencies)

Commitment appropriations in EUR million (to three decimal places)

Indicate

objectives and

outputs



Year 2028

Year 2029

Year 2030

Year 2031

Enter as many years as necessary to show the

duration of the impact (see Section1.6) TOTAL

OUTPUTS

Type3

Avera

ge

cost

N o

Cost N o

Cost N o

Cost N o

Cost N o

Cost N o

Cost N o

Cost Total

No

Total

cost

SPECIFIC OBJECTIVE No 14…

3 Outputs are products and services to be supplied (e.g. number of student exchanges financed, number of km of roads built, etc.). 4 As described in Section 1.3.2. ‘Specific objective(s)’

EN 16 EN

- Output

- Output

- Output

Subtotal for specific objective No 1

TOTALS

EN 17 EN

3.2.3. Summary of estimated impact on administrative appropriations

–  The proposal/initiative does not require the use of appropriations of an administrative nature

–  The proposal/initiative requires the use of appropriations of an administrative nature, as explained below

3.2.3.1. Appropriations from voted budget

VOTED APPROPRIATIONS Year Year Year Year Year Year Year TOTAL 2028

- 2034 2028 2029 2030 2031 2032 2033 2034

HEADING 4

Human resources 0 0 0 0 0 0 0 0

Other administrative expenditure 0 0 0 0 0 0 0 0

Subtotal HEADING 4 0 0 0 0 0 0 0 0

Outside HEADING 4

Human resources 0 0 0 0 0 0 0 0

Other expenditure of an administrative nature 0 0 0 0 0 0 0 0

Subtotal outside HEADING 4 0 0 0 0 0 0 0 0

TOTAL 0 0 0 0 0 0 0 0

The appropriations required for human resources and other expenditure of an administrative nature will be met by appropriations from the DG that are already

assigned to management of the action and/or have been redeployed within the DG, together, if necessary, with any additional allocation which may be granted to the

managing DG under the annual allocation procedure and in the light of budgetary constraints.

3.2.4. Estimated requirements of human resources1

–  The proposal/initiative does not require the use of human resources

–  The proposal/initiative requires the use of human resources, as explained below

1 These redeployment efforts – while fully respecting the stable staffing principle – will likely require deprioritisation of tasks within the Commission services. The

Commission will revisit the needs and the scope for redeployment within the indicated number of staff, following an agreement on the next MFF.

EN 18 EN

3.2.4.1. Financed from voted budget

Estimate to be expressed in full-time equivalent units (FTEs)

VOTED APPROPRIATIONS Year Year Year Year Year Year Year

2028 2029 2030 2031 2032 2033 2034

 Establishment plan posts (officials and temporary staff)

20 01 02 01 (Headquarters and Commission’s

Representation Offices) 21 21 21 21 21 21 21

20 01 02 03 (EU Delegations) 0 0 0 0 0 0 0

(Indirect research) 0 0 0 0 0 0 0

(Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) 0 0 0 0 0 0 0

• External staff (in FTEs)

20 02 01 (AC, END from the ‘global envelope’) 2 2 2 2 2 2 2

20 02 03 (AC, AL, END and JPD in the EU Delegations) 0 0 0 0 0 0 0

Admin. Support line • at Headquarters 0 0 0 0 0 0 0

[XX.01.YY.YY] • in EU Delegations 0 0 0 0 0 0 0

(AC, END - Indirect research) 0 0 0 0 0 0 0

(AC, END - Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) - Heading 4 0 0 0 0 0 0 0

Other budget lines (specify) - Outside Heading 4 0 0 0 0 0 0 0

TOTAL 23 23 23 23 23 23 23

EN 19 EN

To ensure successful delivery and proper implementation of this proposal, an additional redeployment of Commission staffing will be required to meet the

full need.

DG CLIMA needs a total of 23 FTEs to ensure the implementation of the proposal in full. This will ensure adequate management and coordination of

Commission internal implementation, development of tools and guidance documents, support to Member States and monitoring of progress. In line with

the stable staffing principle, the human resources required for this proposal will be covered by internal redeployment within the Commission. At this stage,

of the 23 FTE posts needed, DG CLIMA is in the position to repurpose 13 available permanent posts in the concerned unit.

The staff required to implement the proposal (in FTEs):

To be covered by

current staff

available in the

Commission

services

Exceptional additional staff*

To be financed

under Heading 4

or Research

To be financed

from BA line

To be financed

from fees

Establishment

plan posts

23 in CLIMA

N/A

External staff

(CA, SNEs, INT)

Description of tasks to be carried out by:

Officials, temporary and external

staff

The tasks carried out pertain to the management and coordination of Commisison

internal implementation, development of tools, support to Member States and

monitoring.

In CLIMA, 3 FTE are needed to ensure policy alignment and support for the uptake of

the climate risk assessments across the Commission policy areas; 6 FTE would offer

EN 20 EN

support SG in ensuring policy coherence; 3 FTE would be needed to oversee and

direct the development of the tools that support the implementation of the initiative; 8

FTEs would be needed to ensure coordination with Member States and development of

relevant guidance documents; and 3 FTEs would ensure development of indicators,

monitoring and evaluation.

This number also reflects the fact that climate resilience is of direct relevance to all

policy areas and therefore requires a minimum capacity within DG CLIMA to engage

with the policy risk owners in other DGs.

3.2.5. Overview of estimated impact on digital technology-related investments

The initiative does not entail dedicated digital investment, and the development of any digital outputs is intrinsically tied and part of the

package that is predominantly related to the content development under the initiative; therefore, it is represented as part of the operational

expenditure.

TOTAL Digital and IT

appropriations

Year Year Year Year Year Year Year TOTAL MFF

2028 - 2034

2028 2029 2030 2031 2032 2033 2034

HEADING 4

IT expenditure (corporate) 0 0 0 0 0 0 0 0

Subtotal HEADING 4 0 0 0 0 0 0 0 0

Outside HEADING 4

Policy IT expenditure on operational programmes

0 0 0 0 0 0 0 0

Subtotal outside HEADING 4 0 0 0 0 0 0 0 0

EN 21 EN

TOTAL 0 0 0 0 0 0 0 0

3.2.6. Compatibility with the current multiannual financial framework

The proposal/initiative:

–  can be fully financed through redeployment within the relevant heading of the multiannual financial framework (MFF)

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the next

multiannual financial framework. The source of financing and scope of Union financial commitment in the post-2027 period remain subject to

the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the annual budgetary

procedure. All appropriations and staffing allocations as of 2028 are indicative.

–  requires use of the unallocated margin under the relevant heading of the MFF and/or use of the special instruments as defined in the

MFF Regulation

–  requires a revision of the MFF

3.2.7. Third-party contributions

The proposal/initiative:

–  does not provide for co-financing by third parties

–  provides for the co-financing by third parties estimated below:

Appropriations in EUR million (to three decimal places)

Year Year Year Year Year Year Year

Total 2028 2029 2030 2031 2032 2033 2034

EN 22 EN

Specify the co-financing

body

TOTAL appropriations

co-financed

3.2.8. Estimated human resources and the use of appropriations required in the European Environment Agency2

The amount of appropriations to be allocated to the agency in the next MFF is indicative and subject to the agreement on the MFF. It should be

integrated into the Agency’s subsidy due to the permanent nature of the tasks allocated by this proposal and will be compensated, if relevant, by an

equivalent reduction of a relevant programme envelope under the same MFF heading. If a compensatory reduction is needed, the resources allocated to

the Agency may also need to be revised through the annual budgetary procedure.

Staff requirements (full-time equivalent units)

Agency: EEA Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034

Temporary agents

(AD Grades) 12 12 12 12 12 12 12

Temporary agents

(AST grades)

Temporary agents

(AD+AST) subtotal 12 121212121212

Contract agents 2 2 2 2 2 2 2

2 These redeployment efforts – while fully respecting the stable staffing principle – will likely require deprioritisation of tasks within the European Environment Agency. The

Commission will revisit the needs and scope for redeployment within the indicated number of staff, following an agreement on the next MFF.

EN 23 EN

Seconded national experts

Contract agents and

seconded national experts

subtotal

2 222222

TOTAL staff 14 14 14 14 14 14 14

Appropriations covered by the EU budget contribution in EUR million (to three decimal places)

Agency: EEA Year 2028 Year 2029 Year 2030 Year 2031 Year 2032 Year 2033 Year 2034 TOTAL

2028 - 2034

Title 1: Staff expenditure 0 0 0 0 0 0 0 0

Title 2: Infrastructure and

operating expenditure 0 0 0 0 0 0 0 0

Title 3: Operational expenditure 0 0 0 0 0 0 0 0

TOTAL of appropriations

covered by the EU budget 0 0 0 0 0 0 0 0

Overview/summary of human resources and appropriations (in EUR million) required by the proposal/initiative in a decentralised agency

Agency: EEA Year 2028 Year 2029 Year 2030 Year 2031 Year 2032 Year 2033 Year 2034 TOTAL

2028 - 2034

Temporary agents (AD+AST) 12 12 12 12 12 12 12 12

EN 24 EN

Contract agents 2 2 2 2 2 2 2 2

Seconded National Experts 0 0 0 0 0 0 0 0

Total Staff 14 14 14 14 14 14 14 14

Appropriations covered by the EU

Budget 0 0 0 0 0 0 0 0

Appropriations covered by fees 0 0 0 0 0 0 0 0

Appropriations co-financed (if

applicable) 0 0 0 0 0 0 0 0

Total appropriations 0 0 0 0 0 0 0 0

The EEA will repurpose the existing 11 posts from within agency staff. It will need 12 additional permanent posts and 2 additional contract agent posts

to ensure the implementation of the proposal in full, notably with regards to development of the EUCRA, tools and knowledge development,

monitoring and support to Member States. For the posts that are currently financed through SLAs and other temporary contractual arrangements with

the Commission, the financing should be offset from the relevant programme managed by the relevant Commission services.

3.2.9. Estimated human resources and the use of appropriations required in the EIOPA

The amount of appropriations to be allocated to the agency in the next MFF is indicative and subject to the agreement on the MFF. It should be

integrated into the Agency’s subsidy due to the permanent nature of the tasks allocated by this proposal and will be compensated, if relevant, by an

equivalent reduction of a relevant programme envelope under the same MFF heading. If a compensatory reduction is needed, the resources allocated to

the Agency may also need to be revised through the annual budgetary procedure.

Staff requirements (full-time equivalent units)

EN 25 EN

Agency: EIOPA Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034

Temporary agents

(AD Grades) 3 3 3 3 3 3 3

Temporary agents

(AST grades)

Temporary agents

(AD+AST) subtotal

Contract agents

Seconded national

experts

Contract agents and

seconded national

experts subtotal

TOTAL staff 3 3 3 3 3 3 3

Appropriations covered by the EU budget contribution in EUR million (to three decimal places)

Agency: EIOPA Year 2028 Year 2029 Year 2030 Year 2031 Year 2032 Year 2033 Year 2034 TOTAL

2028 - 2034

EN 26 EN

Title 1: Staff expenditure 0 0 0 0 0 0 0 0

Title 2: Infrastructure and

operating expenditure 0 0 0 0 0 0 0 0

Title 3: Operational expenditure 0 0 0 0 0 0 0 0

TOTAL of appropriations

covered by the EU budget 0 0 0 0 0 0 0 0

Overview/summary of human resources and appropriations (in EUR million) required by the proposal/initiative in a decentralised agency

Agency: EEA Year 2028 Year 2029 Year 2030 Year 2031 Year 2032 Year 2033 Year 2034 TOTAL

2028 - 2034

Temporary agents (AD+AST) 3 3 3 3 3 3 3 3

Contract agents 0 0 0 0 0 0 0 0

Seconded National Experts 0 0 0 0 0 0 0 0

Total Staff 3 3 3 3 3 3 3 3

Appropriations covered by the

EU Budget 0 0 0 0 0 0 0 0

Appropriations covered by fees 0 0 0 0 0 0 0 0

Appropriations co-financed (if

applicable) 0 0 0 0 0 0 0 0

Total appropriations 0 0 0 0 0 0 0 0

EN 27 EN

EIOPA will need three additional posts to establish and manage the Observatory for Catastrophe Risk Insurability. The financing should be offset from

the relevant programme managed by the relevant Commission services.

3.3. Estimated impact on revenue

–  The proposal/initiative has no financial impact on revenue.

–  The proposal/initiative has the following financial impact:

–  on own resources

–  on other revenue

–  please indicate, if the revenue is assigned to expenditure lines

EUR million (to three decimal places)

Budget revenue line:

Appropriations available

for the current financial

year

Impact of the proposal/initiative3

Year 2028 Year 2029 Year 2030 Year 2031 Year 2032 Year 2033 Year 2034

Article ………….

For assigned revenue, specify the budget expenditure line(s) affected.

Other remarks (e.g. method/formula used for calculating the impact on revenue or any other information).

3 In the case of traditional own resources (customs duties, sugar levies), the amounts indicated must be net amounts, i.e. gross amounts after deduction of 10 % for collection

costs, as proposed in COM(2025)574.

EN 28 EN

4. DIGITAL DIMENSIONS

4.1. Requirements of digital relevance

Reference to the

requirement of digital

relevance

Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

Requirement 1: Article 5(1) Article 5(1) requires the

European Environment

Agency to carry out a

European climate risk

assessment at Union-level

European Environment

Agency

The conducting of a

European climate risk

assessment requires the

collection and analysis of

climate resilience data

from Member States

(1) data

Requirement 2: Article 5(2) Article 5(2) requires

Member States to carry out

national climate risk

assessments

Member States The conducting of a

national climate risk

assessment requires the

collection and analysis of

climate resilience data

from Member States

(1) data

Requirement 3: Article 5(4) Article 5(4) requires

Member States and the

European Environment

Agency to publish the

climate risk assessments

Member States, the

European Environment

Agency and the general

public

Requires the publication

of climate risk

assessments

(1) data

Requirement 4: Article 7(5)Article 7(5) requires

Member States to make the

national strategic plan on

climate resilience available

Member States and the

general public

Requires the publication

of national strategic plans

on climate resilience

(1) data

EN 29 EN

to the public

Requirement 5: Article 9 Article 9 requires the

Commission to ensure the

availability of an online

platform on climate

resilience knowledge to

facilitate the

implementation of this

Regulation and to provide

access to information on

climate resilience and

climate risks

Commission, Member

States and the general

public

The making available of

an online platform

(1) data (2) digital public

services

Requirement 6: Article 11Article 11 requires the

EEA to assist the

Commission with climate

resilience data, compiling

information of Member

States national climate

resilience and adaptation

measures and support for

the online platform on

measures and support for

the online platform on

climate resilience

knowledge

EEA, Commission Requires the EEA to assist

Commission

(1) data

Requirement 7: Article 14

Article 14 requires the

Commission to submit a

report to Parliament &

Council on operation of

Commission, the

European Parliament, the

Council

Requires the submission

of progress report of

progress towards the

climate resilience

(1) data

EN 30 EN

this Regulation objective, including for

the policy areas

4.2. Data

The European climate risk assessment is based on climate and environmental data, and socio-economic data. In line with the objectives of European

data strategy as it supports the re-use of data, the EUCRA will be based on the authoritative data from various European sources such as Copernicus

services, Destination Earth and the JRC Risk data hub, and the sources available and maintained by the research institutions. Stakeholders will be

receiving the data directly from original sources or aggregated data from the existing data platforms managed by the EEA and the European

Commission. The data for EUCRA will be integrated into Climate-ADAPT and since Climate-ADAPT is the European Union website serving all

governance levels in Europe (from EU to local), the digital services cover multi-level governance of climate risk and resilience, and adaptation.

Alignment with the European Data Strategy

The proposal is aligned with the European Data Strategy as it will improve comparability and accessibility of relevant data across EU and Member

States.

Alignment with the once-only principle

The proposal follows the once-only principle, notably by using a single existing and simplified reporting channel for Member States.

Explanation of how newly created data are findable, accessible, interoperable and reusable, and meets high-quality standards

New data will be accessible through relevant platforms, that will be developed with usability and interoperability as core considerations. Data will be

subject to quality checks.

Data Flows Table 1

Type of Data Reference to the requirements Standard and/or specification (if applicable)

European climate risk assessment Article 5(1) The contents set out in Annex II, Annex III

National climate risk assessment Article 5(2) The contents set out in Annex II, Annex III

EN 31 EN

Publication of risk assessments Article 5(4) The contents set out in Annex II, Annex III

National strategic plan on climate resilience Article 7(2) The contents set out in Annex III, IV

Establishment of online platform on climate

resilience knowledge

Article 9 n/a

Assistance with compilation and analysis of

information from Member States on climate

resilience policies and measures

Article 11 n/a

Commission report to Parliament & Council

on operation of this Regulation

Article 15 n/a

Data Flows Table 2

Type of Data Reference to

legislation

Actors who

provide the

data

Actors who

receive the

data

Trigger for

data exchange

Frequency of data exchange

European climate risk

assessment

5(1), 5(4),

Annex II,

Annex III

Member

States

EEA deadline of 30

June 2028

Reviewed every 5 years thereafter

National climate risk assessment 5(2), 5(4),

Annex II,

Annex III

Member

States

Member

States deadline of 30

June 2029

Reviewed every 5 years thereafter

EN 32 EN

Climate risk assessment

(published/publicly available)

Article 5(4) EEA /

Member

States

general

public

After their

finalisation

Union strategic plan on climate

resilience

Articles 6(1),

6(2), 6(3),

Annex III,

Annex IV

Commission Adopted by

deadline of 30

September 2028

30 September 2033 evaluated and updated

every 5 years thereafter

National strategic plan on

climate resilience

Articles 7(1) to

7(6), Annex

III, Annex IV

Member

States

Adopted by

deadline of 31

December 2030

Evaluated and updated every 5 years

Online platform Article 9 Commission

Compilation and analysis of

information from Member

States on climate resilience

policies and measures

Article 11 Member

States

EEA

Commission report to

Parliament & Council on

operation of this Regulation

Article 15 Commission European

Parliament &

Council

Deadline of 30

September 2033

Reporting under Governance

Regulation 2018/1999

Article 14(4) Member

States

Commission Deadline of

March 2029

Every two years thereafter

EN 33 EN

4.3. Digital solutions

4.4. Interoperability assessment

The online platform on climate resilience knowledge (Article 9) will build on existing Union digital infrastructures and services, in particular

Climate-ADAPT, the Copernicus services, the JRC Risk Data Hub and Destination Earth, as well as other relevant sources

Digital public service or

category of digital public

services

DescriptionReference(s) to

the

requirement

Interoperable

Europe Solution (s)

Other interoperability

solution(s)

Online platform Establishment of online platform on

climate resilience knowledge

Article 9 The tools published

on the online

platform should be

interoperable

among themselves

Assess the impact of the requirement(s) on cross-border interoperability

Assessment Measure(s) Potential remaining barriers

Online platform

The online platform will

provide access to tools. These

tools published on the online

platform should be

interoperable among

themselves

EN 34 EN

4.5. Measures to support digital implementation

Description of the measure Reference to the

requirement(s)

Commission

role (if

applicable)

Actors to be

involved (if

applicable)

Expected timeline (if

applicable)

Digital implementation is a core part of development of

the support tools, and specific additional needs support

will be identified in the relevant process

EN EN

EUROPEAN COMMISSION

Brussels, 27.10.2026 COM(2026) 730 final

ANNEXES 1 to 5

ANNEXES

to the

Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE

COUNCIL

establishing a framework to enhance climate resilience and amending Regulation (EU)

2018/1999 (European Climate Resilience Law)

{SEC(2026) 730 final} - {SWD(2026) 730 final} - {SWD(2026) 731 final} - {SWD(2026) 732 final}

EN 1 EN

ANNEX I

REFERENCE GLOBAL WARMING TRAJECTORY

The values of the reference global warming trajectory referred to in Article 4 are defined as

increases in multi-decadal global average surface temperature of 1,5 °C by 2030, 2 °C by

2050 and 3 °C by the end of the 21st century, relative to pre-industrial levels (defined as the

average over the 1850–1900 period).

EN 2 EN

ANNEX II

CONTENT OF THE CLIMATE RISK ASSESSMENTS PURSUANT TO ARTICLE 5

1. Identification of major climate risks across at least a near, medium and long-term

timeframe, based on at least the following:

(a) relevant current and future climate hazards;

(b) several climate change scenarios, including the reference global warming

trajectory set out in Article 4;

(c) extremes, tail risks and tipping points;

(d) exposure and climate vulnerability of the systems affected;

(e) systemic climate risks, including transboundary, cascading and compounding

climate risks;

(f) the policy areas affected, including at least those of Union-wide relevance for

climate resilience set out in Annex III;

(g) description of how people in vulnerable situations and communities

disproportionately affected by climate risks have been taken into consideration;

(h) description of how regions and territories disproportionately affected by

climate risks have been taken into consideration;

(i) the climate risks identified and their severity.

2. Evaluation of the urgency of each identified major climate risk, based on an analysis

of the extent to which current and planned policy actions will be able to manage each

those risks, taking into account the policy horizon, readiness and policy risk

ownership.

3. Identification of options for policy action for each major climate risk identified,

based on:

(a) synergies with other relevant policies and processes;

(b) the effectiveness and efficiency of each option under the reference global

warming trajectory set out in Article 4 and under other climate projections,

including by stress testing of the options in more adverse climate projections;

(c) the level of residual risk for each option.

EN 3 EN

ANNEX III

LIST OF POLICY AREAS OF UNION-WIDE RELEVANCE FOR CLIMATE

RESILIENCE TO BE ADDRESSED IN CLIMATE RISK ASSESSMENTS UNDER

ARTICLE 5 AND STRATEGIC PLANS UNDER ARTICLES 6 AND 7

1. Spatial planning;

2. Critical energy systems;

3. Critical transport systems;

4. Critical communication systems;

5. Water security and critical water infrastructure systems;

6. Buildings;

7. Public health;

8. Food security;

9. Economic and social policies;

10. Budgetary policies;

11. Financial systems;

12. Crisis preparedness, response systems and solidarity mechanisms;

13. Ecosystems and ecosystem services and biodiversity.

EN 4 EN

ANNEX IV

CONTENT OF STRATEGIC PLANS ON CLIMATE RESILIENCE PURSUANT TO

ARTICLES 6 AND 7

SECTION 1

HORIZONTAL PLANNING

1. Horizontal priorities of the strategic plan;

2. Use of the reference global warming trajectory referred to in Article 4 and other

climate change scenarios;

3. Tolerability of the level of residual risks expected to remain after the implementation

of the plan;

4. Governance arrangements for the implementation of the strategic plan including,

with respect to national strategic plans, at national, regional and local level;

5. Governance arrangements, with respect to national strategic plans, at national,

regional and local level for embedding climate resilience considerations into

exercising public functions;

6. Public authorities responsible for addressing each major climate risk identified in the

national climate risk assessment referred to in Article 5(2);

7. Description of how people in vulnerable situations and communities

disproportionately impacted by climate risks have been taken into consideration;

8. Description of how regions and territories disproportionately impacted by climate

risks have been taken into consideration;

9. Assessment of consistency of the strategic plans with other Union strategies and

plans including those which are relevant to the policy areas of Union-wide relevance

for climate resilience listed in Annex III;

10. Assessment of consistency of the national strategic plans with the Union strategic

plans referred to in Article 6 and other relevant national strategies and plans,

including those which are relevant to the policy areas of Union-wide relevance for

climate resilience listed in Annex III and, where appropriate, the national strategic

plans of the neighbouring Member States referred to in Article 8;

11. Investment needs, indicative sources of financing and measures for the

implementation of the plan.

SECTION 2

POLICY AREA PLANNING

12. Climate resilience objectives and targets, where relevant, for each policy area of

Union-wide relevance for climate resilience listed in Annex III, including at least the

following for each objective and target:

(a) the timeframe for their achievement;

(b) progress monitoring indicators.

13. Based on the reference global warming trajectory referred to in Article 4, a

description of the measures to achieve the objectives and targets set out under point

EN 5 EN

11 and to address major climate risks identified, (i) with respect to the Union

strategic plans referred to in Article 6, in the European climate risk assessment

referred to in Article 5(1) and, (ii) with respect to national strategic plans referred to

in Article 7, in the national climate risk assessments referred to in Article 5(2),

setting out for each measure, the following:

(a) the competent authorities or other responsible entities;

(b) the timeframe for implementation;

(c) the tolerability of the level of residual risk expected to remain after the

implementation of the measures and description of how maladaptation is

avoided;

(d) their expected costs and benefits, including non-monetary benefits, their cost-

effectiveness and relevant fiscal and budgetary constraints, where appropriate

and proportionate.

14. An explanation of the set of measures selected under point 13, in view of the options

for policy action identified in,

(a) with respect to Union strategic plans referred to in Article 6, in the climate risk

assessment referred to in Article 5(1);

(b) with respect to national strategic plans referred to in Article 7, in the climate

risk assessments referred to in Article 5(2).

EN 6 EN

ANNEX V

UNION-LEVEL INDICATORS ON CLIMATE RESILIENCE

Indicator Unit of Measurement Frequency of

measurement

1. Loss of life attributable to

climate change in the Member

State

Number Annual

2. Economic losses attributable

to climate change,

disaggregated by Member State

and policy areas as feasible

EUR Annual

3. Share of uninsured climate-

related economic losses % Annual

4. Climate-related contingent

liabilities and fiscal costs in the

Member States*

EUR Annual and multiannual

* Published by Member States under the budgetary processes in accordance with Article 14(3) of the

Council Directive 2011/85/EU of 8 November 2011 on requirements for budgetary frameworks of the

Member States (OJ L 306 23.11.2011, p. 41).

EN EN

EUROPEAN COMMISSION

Brussels, 27.10.2026 SWD(2026) 730 final

COMMISSION STAFF WORKING DOCUMENT

Subsidiarity Grid

Accompanying the document

Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE

COUNCIL

establishing a framework to enhance climate resilience and amending Regulation (EU)

2018/1999 (European Climate Resilience Law)

{COM(2026) 730 final} - {SEC(2026) 730 final} - {SWD(2026) 731 final} - {SWD(2026) 732 final}

1

Subsidiarity Grid

1. Can the Union act? What is the legal basis and competence of the Unions’ intended action?

1.1 Which article(s) of the Treaty are used to support the legislative proposal or policy initiative?

The legal basis for this proposal is Article 192 of the Treaty on the Functioning of the European Union (TFEU). In accordance with Articles 191 and 192(1) TFEU, the European Union shall contribute to pursuit, inter alia, the following objectives: preserving, protecting and improving the quality of the environment; protecting human health, promoting measures at international level to deal with regional or worldwide environmental problems, and in particular combating climate change.

1.2 Is the Union competence represented by this Treaty article exclusive, shared or supporting in nature?

In the case of environment, the Union’s competence is shared.

2. Subsidiarity Principle: Why should the EU act?

2.1 Does the proposal fulfil the procedural requirements of Protocol No. 21:

- Has there been a wide consultation before proposing the act?

- Is there a detailed statement with qualitative and, where possible, quantitative indicators allowing an appraisal of whether the action can best be achieved at Union level?

Several consultation activities were carried out to make stakeholders and the general public aware of the initiative, and to gather their input.

The types of consultation activities were as follows:

• Call for Evidence

• Open Public consultation

1 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12016E/PRO/02&from=EN

2

• Special groups of the Commission

• Public events and conferences

• Meetings and seminars

The Call for Evidence was open from the 24 July 2025 to 4 September 2025 on the Commission’s ‘Have your say portal’ and received a total of 233 replies. The public consultation was open from 1 December 2025 to 23 February 2026, and 670 responses were submitted to this public consultation through the EU Survey portal. Additionally, a total of 31 individuals/companies complemented their responses or contributed separately their views through position papers and/or additional material.

Discussions with Member States were held in different formations: in the Working Party on the Environment (WPE) at the EU Council, within the European Climate Policy Group (ECPG), through the Working Group on Adaptation (WGA) and in events. Engagement with the European Parliament was carried out through the Committee on Environment, Public Health and Food Safety (ENVI), complemented by a series of bilateral meetings and participation in relevant parliamentary events. Dialogues were held with the Committee of the Regions and the European Economic and Social Committee, and their Opinions contributed to the development of the impact assessment. Exchanges with other EU entities, such as the European Environment Agency (EEA), European Investment Bank (EIB) and the European Scientific Advisory Board on Climate Change (ESABCC), as well as their respective reports also fed into the initiative.

Other groups, initiatives and events also contributed to the initiative, such as the Commission’s Climate Resilience Dialogue, the Reflection Group on Mobilising Climate Resilience Financing, the Industrial Forum, a European roundtable on managing climate risks and a hybrid event with Youth representatives. More details can be found in Annex 2 of the Impact Assessment (SWD(2026) 731).

Furthermore, the explanatory memorandum (section 2) and Chapter 3 of the impact assessment report present qualitative indicators enabling an assessment of the need to act at Union level.

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2.2 Does the explanatory memorandum (and any impact assessment) accompanying the Commission’s proposal contain an adequate justification regarding the conformity with the principle of subsidiarity?

The explanatory memorandum of the proposal (under section 2) and the impact assessment (under section 3), contain sections on the principle of subsidiarity. They explain that climate change and related impacts and risks are inherently transboundary in nature. Many climate risks, including disruptions to interconnected infrastructure, supply chains, ecosystems and financial systems, extend across national borders and cannot be effectively addressed through isolated action by individual Member States. Coordinated action at Union level can complement and reinforce national, regional and local measures and improve the overall effectiveness of climate resilience efforts.

Therefore, EU action is justified on grounds of subsidiarity as set out in Article 5 TFEU. Climate impacts and risks can undermine the effective delivery of EU policies including the functioning of the single market, as well as the Union’s ability to uphold its fundamental rights and pursue its international obligations and promote more ambitious approaches internationally. Policy intervention at the EU level - in concert with national, regional and local action - is necessary to achieve sufficient levels of systemic, EU-wide climate resilience and preparedness levels effectively.

2.3 Based on the answers to the questions below, can the objectives of the proposed action be achieved sufficiently by the Member States acting alone (necessity for EU action)?

The proposal sets a climate resilience objective for the Union and each Member State to continuously enhance the climate resilience of social, economic and ecological systems against short-, medium- and long-term climate risks within the Union, in particular with regard to risks to human life and health, to economy and infrastructure, and to nature and ecosystems. A Union objective cannot be achieved by the Member States alone as it requires EU level action. The transboundary nature of climate risks also requires a coherent approach across the Union to effectively strengthen preparedness.

(a) Are there significant/appreciable transnational/cross-border aspects to the problems being tackled? Have these been quantified?

Many climate risks, including disruptions to interconnected infrastructure, supply chains, ecosystems and financial systems, extend across national borders and

4

cannot be effectively addressed through isolated action by individual Member States. Coordinated action at Union level can complement and reinforce national, regional and local measures and improve the overall effectiveness of climate resilience efforts. Quantification is challenging, as it is linked to the uncertainties in projected futures, notably regarding climatic impacts, policy developments and implementation across sectors both at EU and Member States’ level.

While it is not possible to quantify precisely the significant cross-border dimension of all climate risks, such cross-border effects are inherent to the nature of climate risks themselves.

For example, in 2024 flooding alone caused EUR 31.1 billion in losses across the EU, annual losses from droughts are amounting to EUR 9 billion and are spread unevenly across Member States (details and sources in the impact assessment).

(b) Would national action or the absence of the EU level action conflict with core objectives of the Treaty2 or significantly damage the interests of other Member States?

Urgent strengthening of climate resilience across the Union and across all policy areas is necessary to prepare for climate risks caused by climate change and is therefore necessary to fulfil the objectives of Article 192 TFEU, in particular preserving, protecting and improving the quality of the environment, protecting human health and combating climate change. National action alone, or the absence of Union-level action, would risk creating fragmented and uneven approaches to climate resilience, thereby undermining the effective achievement of these Treaty objectives. It could also significantly affect the interests of Member States, given that climate impacts and adaptation gaps in one Member State may have spill-over effects on interconnected ecosystems, infrastructure, supply chains and markets across the Union.

(c) To what extent do Member States have the ability or possibility to enact appropriate measures?

The role of Member State action is crucial to achieve the overall Union objective of strengthening climate resilience and addressing climate risks across the Union. Member States have an important role to adopt a strategic plan on climate resilience and implementing measures. The proposal does not prescribe specific policies or measures but leaves Member States the flexibility to determine and implement the

2 https://europa.eu/european-union/about-eu/eu-in-brief_en

5

most appropriate policies and measures needed to achieve the objective of the framework, considering their specific circumstances and existing regulatory frameworks.

(d) How does the problem and its causes (e.g. negative externalities, spill-over effects) vary across the national, regional and local levels of the EU?

The effects of climate change are present across national, regional and local levels throughout the EU. Their nature, scale and drivers, however, vary significantly depending on geographic, climatic, environmental, economic and social conditions. Vulnerability to climate change and concrete climate risks therefore differ according to regional and local circumstances. For example, some areas are more exposed to coastal erosion and sea level rise, others to drought, wildfires, flooding or heat stress, with impacts differing further depending on land use, infrastructure, ecosystems and population density. At the same time, climate risks can generate negative externalities and spill-over effects beyond the level at which they arise, including through shared ecosystems, river basins, infrastructure networks, energy systems, markets and supply chains. Member States are therefore given considerable flexibility in how they can strengthen climate resilience within their territories, as there is no one-size-fits- all solution.

(e) Is the problem widespread across the EU or limited to a few Member States?

The need to strengthen preparedness and improve the management of climate risks is widespread across the EU and affects all Member States. While the nature and severity of climate risks vary between Member States, no Member State is unaffected. In the current situation, preparedness for climate impacts and risks is fragmented and insufficient across the European economy and society in the absence of a coherent and comparable framework for assessing and managing climate risks. Member States currently use different and inconsistent methodologies, climate scenarios, warming trajectories, assessment cycles and sectoral coverage. As a result, climate risks are identified and managed inconsistently, leading to uneven levels of preparedness and making it more difficult to address shared and transboundary climate risks effectively.

(f) Are Member States overstretched in achieving the objectives of the planned measure?

6

The proposal establishes a common framework for strengthening climate resilience and addressing climate risks across the Union. Based on the impact assessment, the initiative does not prescribe specific policies or measures, leaving Member States the flexibility to determine the policies and measures needed to achieve the objective of the framework and to decide what is the most efficient way for achievement and implementation considering their specific circumstances and existing regulatory frameworks. The proposal is designed to support and guide national action through a coherent Union framework while respecting national flexibility and administrative capacities.

(g) How do the views/preferred courses of action of national, regional and local authorities differ across the EU?

Most public authorities across the Union welcome the goal of the framework to strengthen climate resilience across the Union. In particular, regional and local authorities have called for more support and there is broad recognition at national, regional and local level of the need to improve preparedness and resilience to climate risks.

2.4 Based on the answer to the questions below, can the objectives of the proposed action be better achieved at Union level by reason of scale or effects of that action (EU added value)?

The objective of the proposed action can be better achieved at Union level by reason of the cost efficiency of action on climate adaptation, coherence of EU action, preserved functioning of the internal market and strengthened EU position to foster global action on climate resilience.

(a) Are there clear benefits from EU level action?

The benefits from EU level actions relate to the explanations below.

(b) Are there economies of scale? Can the objectives be met more efficiently at EU level (larger benefits per unit cost)? Will the functioning of the internal market be improved?

Strengthening climate resilience across the Union benefits from coordination at EU level, notably in view of the EU’s single market and the cross-sectoral nature of climate risks. In particular, the Regulation plays a crucial role in safeguarding the

7

functioning of the single market against future climate risks. A more coherent Union framework can reduce fragmentation, improve comparability of risk assessments and support more predictable conditions for public and private investment. Improving the functioning of the internal market for climate resilience products and services (e.g. heat-protection gear for workers, drought resistant crops, smart building cooling solutions) holds potential for economies of scale, greater competitiveness at the global scale, and better leverage over global norms and regulatory standards. Union- level action can therefore help achieve the objective more efficiently by facilitating the sharing of data, methodologies and best practices, and supporting more consistent market conditions across Member States.

(c) What are the benefits in replacing different national policies and rules with a more homogenous policy approach?

Given the transboundary nature of climate hazards, policy intervention at the EU level – in concert with national, regional and local action - is necessary to achieve sufficient levels of systemic, EU-wide climate resilience and preparedness effectively and efficiently. Furthermore, the Regulation establishes common parameters for climate risk assessments, planning and methodology to ensure greater consistency across the Union. Replacing divergent national approaches with a more homogeneous policy framework improves comparability, reduces fragmentation, facilitates cooperation on shared and cross-border risks, and supports more coherent action by public authorities and market actors across the Union.

(d) Do the benefits of EU-level action outweigh the loss of competence of the Member States and the local and regional authorities (beyond the costs and benefits of acting at national, regional and local levels)?

The proposal only contains core elements that need to be applied in a sufficiently uniform manner across all Member States. It does not prescribe specific policies or measures and leaves Member States the flexibility to determine the policies and measures needed to achieve the objective of the framework, considering their specific circumstances and existing regulatory frameworks. The proposal ensures the consistency needed to address cross-border climate risks and fragmentation. It also requires clarity on responsibilities (risk ownership), while preserving broad flexibility for Member States to choose how to implement the framework in practice. The measure is thus limited to what is necessary to achieve its objective and respects the roles and competences of national, regional and local authorities.

8

(e) Will there be improved legal clarity for those having to implement the legislation?

The proposal ensures legal clarity for those having to implement the legislation by establishing a clear common framework for climate risk assessment, planning and monitoring across the Union.

3. Proportionality: How the EU should act

3.1 Does the explanatory memorandum (and any impact assessment) accompanying the Commission’s proposal contain an adequate justification regarding the proportionality of the proposal and a statement allowing appraisal of the compliance of the proposal with the principle of proportionality?

The explanatory memorandum explains that the proposal complies with the proportionality principle. The proposal does not go beyond what is necessary for achieving the objective of continuously enhancing the climate resilience of social, economic and ecological systems against short-, medium- and long-term climate risks within the Union. Proportionality is also analysed throughout the impact assessment accompanying the proposal.

3.2 Based on the answers to the questions below and information available from any impact assessment, the explanatory memorandum or other sources, is the proposed action an appropriate way to achieve the intended objectives?

The proposal is the appropriate and proportionate way to achieve the intended objective of strengthening climate resilience across the Union. It ensures a harmonised approach while setting common criteria for climate risk assessments and planning. It addresses a problem that is widespread across the Union, including significant cross-border dimensions, and where fragmented national approaches would undermine effectiveness and the functioning of the internal market. At the same time, the proposal is limited to establishing a common framework and core requirements, without prescribing specific national measures, thereby preserving flexibility for Member States, to act in line with their particular circumstances.

(a) Is the initiative limited to those aspects that Member States cannot achieve satisfactorily on their own, and where the Union can do better?

9

Setting a Union and Member State objective and providing a harmonised approach on climate risk assessments and planning cannot be done by Member States on their own.The initiative, in line with the impact assessment qualitative and quantitative analysis, is limited to those aspects where Union action can clearly provide added value, notably by reducing fragmentation between national approaches, improving comparability and consistency, and supporting the functioning of the internal market, without exceeding what is necessary.

(b) Is the form of Union action (choice of instrument) justified, as simple as possible, and coherent with the satisfactory achievement of, and ensuring compliance with the objectives pursued (e.g. choice between regulation, (framework) directive, recommendation, or alternative regulatory methods such as co-legislation, etc.)?

The proposal defines a framework for strengthening climate resilience across the Union and each Member State. A Regulation ensures greater consistency and coherence across the Union. This is particularly important here as the proposal contains core elements that need to be applied in a sufficiently uniform manner across all Member States. This includes requirements relating to national climate risk assessments, national strategic plans and the integration of climate resilience into relevant policies. The choice of a Regulation is justified because it provides a directly applicable and sufficiently uniform framework, thereby reducing the risk of divergent transposition and implementation that could arise under other instruments. This contributes to a policy intervention that is as simple as possible, while remaining effective and proportionate to the objective pursued. At the same time, the proposal is limited to setting a common objective and core procedural requirements, without harmonising in detail the substantive national measures to be taken, thereby preserving flexibility for Member States in implementation.

(c) Does the Union action leave as much scope for national decision as possible while achieving satisfactorily the objectives set? (e.g. is it possible to limit the European action to minimum standards or use a less stringent policy instrument or approach?)

The Regulation leaves substantial room for Member States to define their national objectives on climate resilience and to choose implementing measures and thereby it respects different national circumstances while contributing to the overarching climate resilience objective and addressing national climate risks. Union action is

10

therefore limited to what is necessary to achieve the objective satisfactorily, notably through core framework requirements.

(d) Does the initiative create financial or administrative cost for the Union, national governments, regional or local authorities, economic operators or citizens? Are these costs commensurate with the objective to be achieved?

The initiative does not impose direct regulatory obligations or compliance costs on economic operators or citizens. Its primary impacts are on public authorities at EU and Member State level.

One of the main purposes of the proposal is to reduce and avoid economic losses caused by climate change and more concretely caused by the realisation of climate risks and increase the overall preparedness of the Union. As explained in detail in the Impact Assessment, it is difficult to quantify avoided losses at a whole economy level, and the benefits of the individual measures have been mainly characterised in a qualitative way. Whenever possible, quantified costs and benefits were included for measures and policy options at Union and national level. One conservative estimate is that future climate-related GDP loss in the EU could be up to 1% annually in the coming years, 2.3% by 2050, and up to 7% by the end of the century. The climate impacts will affect all economic sectors. Any effective climate resilience building and adaptation action is likely to avoid significant expenditure and lost revenue.

(e) While respecting the Union law, have special circumstances applying in individual Member States been taken into account?

The initiative sets an objective on strengthening climate resilience for the Union and each Member State. Special circumstances that might apply in individual Member States are considered as the proposal leaves considerable flexibility for the relevant Union institutions and the Member States when setting objectives and taking the necessary measures for implementation. This allows Member States to respond to differing national climate risks, governance and administrative structures, economic conditions and existing regulatory frameworks.

EUROPEAN COMMISSION

7.9.2026

SEC(2026) 730

REGULATORY SCRUTINY BOARD OPINION

{COM(2026) 730}

{SWD(2026) 730-732}

Impact assessment / European Integrated Framework for Climate Resilience

________________________________ Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111

[email protected]

EUROPEAN COMMISSION REGULATORY SCRUTINY BOARD

Brussels, RSB

Opinion

Title: Impact assessment / European Integrated Framework for Climate

Resilience

Overall 2nd opinion: POSITIVE WITH RESERVATIONS

(A) Policy context

This initiative aims to address climate resilience as a vital element of wide societal

resilience and preparedness through developing a new EU policy framework for

strengthening climate resilience. The new framework follows the first European Climate

Risk Assessment (EUCRA) and the 2024 Commission Communication on managing

climate risks. The European Integrated Framework for Climate Resilience aims to support

the ability of the EU and its Member States to tackle the significant impacts and risks

identified in the EUCRA. It includes elements such as climate resilience objectives,

common reference global warming trajectory, risk ownership, climate risk management

in sectoral policies, climate resilience by design, minimum requirement for climate risk

assessment, and common parameters for adaptation strategies and plans.

(B) Key issues

The Board notes the improvements to the revised report responding to the Board’s

previous opinion.

However, the report still contains significant shortcomings. The Board gives a

positive opinion with reservations because it expects the lead Service to rectify the

following aspects:

(1) The evidence behind the problem of insufficient physical preparedness and the

interplay between policies and physical preparedness are not clearly presented.

(2) The causal link between options and expected effects, including possible

secondary consequences for private actors, is only partially demonstrated.

(3) The costs and the benefits are not presented sufficiently clearly.

(4) The coherence of the initiative with the post-2030 climate and energy package is

not sufficiently assessed, including as regards potential overlaps, unnecessary

administrative burden and enforcement.

2

(C) What to improve

(1) The problem of fragmented, uneven and insufficient preparedness, and its magnitude

should be more thoroughly substantiated with relevant evidence, in particular as

regards the physical preparedness of the different sectors in Member States. Building

on the available evidence, e.g. from the European Climate Risk Assessment

(EUCRA), the report should present an analysis of the physical preparedness and

resilience of the different sectors to demonstrate gaps in physical preparedness, to

analyse avoidable risks and establish gaps in policies. The problem section should be

streamlined to avoid repetitions.

(2) The report should provide more details on the process and methodology for the

assessment of the residual risks and risk tolerance. The report should better

demonstrate the causal link between the different options, expected effects and better

explain what types of measures will need to be undertaken by different categories of

actors in order for the risks to be reduced below the maximum tolerable level. The

report should provide more detail on the public-sector concepts and envisaged

climate-proof sector standards addressed to the private sector, the implementation

timeframes and the enforcement of each policy option. The report should explain

whether public bodies that are assigned ownership of particular risks may in turn need

to regulate the behaviour of private citizens and businesses in order to address the

risks and achieve the envisaged benefits, and how any related unintended

consequences will be assessed.

(3) The report should better substantiate the calculations of certain costs, e.g. for the

Climate Viewer and Resilience Navigator. The assessment of costs and benefits

should take into account the same types of costs and benefits for each option. The

administrative costs (or costs savings) for the public authorities should be better

estimated and included in the burden reduction table.

(4) Based on an improved analysis of causal links between the different options and their

effects, the report should demonstrate how benefit-cost ratios (BCRs), additional

investments and return on investment (ROIs), used in estimating benefits under the

different options, relate to the specific options and measures. The report should be

transparent on which impacts, both in terms of costs and benefits, will directly stem

from this intervention and which impacts are expected from follow-up interventions.

(5) The report should better describe how the preferred option will be implemented and

enforced. It should also further discuss simplification and streamlining possibilities

with other existing or forthcoming initiatives of the energy and climate framework,

with a view to reducing burden for public authorities and private actors.

The report should better analyse the added value of a compulsory Better regulation

check and should clarify whether it is a part of the preferred option.

3

(D) Conclusion

The lead Service may proceed with the initiative.

The lead Service must revise the report and its executive summary in accordance with

the Board’s findings before launching the interservice consultation.

Full title Proposal for a Regulation of the European Parliament and of the

Council establishing the framework for achieving climate

preparedness and resilience and laying down harmonised rules

on climate risk management, and amending Regulation (EU)

2018/1999 on the Governance of the Energy Union and Climate

Action

Reference number PLAN/2025/1038, PLAN/2025/1040

Submitted to RSB on 10 July 2026

Date of RSB meeting Written procedure

4

EUROPEAN COMMISSION REGULATORY SCRUTINY BOARD

Brussels, RSB

Opinion

Title: Impact assessment / European Integrated Framework for Climate

Resilience

Overall opinion: NEGATIVE

(A) Policy context

This initiative aims to address climate resilience as a vital element of wide societal resilience

and preparedness through developing a new EU policy framework for strengthening climate

resilience. The new framework follows the first European Climate Risk Assessment

(EUCRA) and the 2024 Commission Communication on managing climate risks. The

European Integrated Framework for Climate Resilience aims to support the ability of the EU

and its Member States to tackle the significant impacts and risks identified in the EUCRA.

It includes elements such as climate resilience objectives, common reference global warming

trajectory, risk ownership, climate risk management in sectoral policies, climate resilience

by design, minimum requirement for climate risk assessment, and common parameters for

adaptation strategies and plans.

(B) Key issues

The Board notes the additional information provided and commitments to make

changes to the report.

However, the Board gives a negative opinion because the report contains the following

serious shortcomings that the lead Service must address:

(1) The problem related to the lack of preparedness and its magnitude is not clearly

defined nor sufficiently substantiated with evidence.

(2) The causal pathways from measures to outputs and impacts are not clearly

established. The description of the options is not sufficiently specific and does not

adequately distinguish between mandatory and voluntary measures.

(3) Coherence of the initiative with existing and forthcoming initiatives is not

sufficiently assessed, in particular as regards potential overlaps and unnecessary

administrative burden.

(4) The costs and the benefits resulting from the options are not sufficiently assessed.

The methodology and assumptions behind the effectiveness and efficiency of the

options are not transparent.

5

(C) What to improve

(1) The report should clearly define the scope of the intervention, both in terms of content

and legal instruments. The report should not be limited to noting policy gaps in the

existing legal frameworks or public interventions: based on a better analysis of the

current state of preparedness across the EU, the report should provide more robust

evidence substantiating the analysis of the problem related to lack of preparedness

including its magnitude. The report should analyse better the remaining avoidable risks

at sector level and overall.The report should explain why the existing legislative

framework on climate resilience and adaptation does not suffice to address the identified

societal problems and substantiate the claimed regulatory failure with available

evidence. The report should more clearly differentiate between issues stemming from

lack of rules and those stemming from lack of proper implementation of the rules. The

report should also substantiate the existence of the claimed market failures to be

addressed by the initiative.

(2) The report should be clearer on the causal pathway from measures to outputs, results and

impact, to the extent possible building on available evidence, including from Member

States. The report should specify the measures more clearly and especially be clearer

about which obligations stem from the proposed measures and explain how the different

instruments, including mandatory and voluntary, would interact with each other. The

concept of risk ownership needs to be further analysed, including in terms of its relation

to the rights and responsibilities regarding the assets exposed to climate risks, including

in relation to other actors. The report should clearly specify the envisaged flexibilities

within mandatory obligations and how a harmonised approach to the assessment of

residual risks and the implementation of climate resilience by design will be ensured.

(3) The report should further improve the assessment of coherence with existing and

forthcoming initiatives, including, where relevant, economic governance and sectoral

ones. The report should analyse more in depth the potential for overlaps and increased

regulatory or administrative burden. In particular, the proposed inclusion of climate

resilience check in the better regulation requirements should be revisited in the context

of the simplification agenda and the reduction of administrative burden.

(4) The impact analysis of each option should be transparent about the underpinning

methodology, assumptions and evidence used. The costs and benefits should be further

assessed to include quantitative elements where feasible or at least indicate the order of

magnitude of the identified impacts. Benefits and costs should be reported at the same

level, therefore if benefits are to be realised due to sectoral initiatives, the related costs

should be reflected accordingly.

(5) The report should further strengthen the comparison of options and their scoring based

on the improved assessment of benefits and costs. The key trade-offs between the

options should be more clearly indicated.

Some more technical comments have been sent directly to the author Service.

6

(D) Conclusion

The lead DG must revise the report and its executive summary in accordance with the

Board’s findings and resubmit it for a final RSB opinion.

Full title Proposal for a Regulation of the European Parliament and of the

Council establishing the framework for achieving climate

preparedness and resilience and laying down harmonised rules

on climate risk management, and amending Regulation (EU)

2018/1999 on the Governance of the Energy Union and Climate

Action

Reference number PLAN/2025/1038, PLAN/2025/1040

Submitted to RSB on 22 April 2026

Date of RSB meeting 20 May 2026

Electronically signed on 07/09/2026 16:24 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121

EN EN

EUROPEAN COMMISSION

Brussels, 27.10.2026 SWD(2026) 731 final

PART 1/5

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT REPORT

EU Framework for Climate Resilience

Accompanying the document

Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE

COUNCIL

establishing a framework to enhance climate resilience and amending Regulation (EU)

2018/1999 (European Climate Resilience Law)

{COM(2026) 730 final} - {SEC(2026) 730 final} - {SWD(2026) 730 final} - {SWD(2026) 732 final}

1

Table of contents

1 INTRODUCTION: POLITICAL AND LEGAL CONTEXT ............................................................... 3

2 PROBLEM DEFINITION .................................................................................................................... 5

3 WHY SHOULD THE EU ACT? ........................................................................................................ 30

4 OBJECTIVES: WHAT IS TO BE ACHIEVED? ............................................................................... 32

5 WHAT ARE THE AVAILABLE POLICY OPTIONS? .................................................................... 34

6 WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ........................................................... 49

7 HOW DO THE OPTIONS COMPARE? ............................................................................................ 75

8 PREFERRED OPTION ...................................................................................................................... 81

9 HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................................. 90

ANNEX 1: PROCEDURAL INFORMATION .......................................................................................... 117

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) .............................................. 122

ANNEX 3: WHO IS AFFECTED AND HOW? ........................................................................................ 142

ANNEX 4: ANALYTICAL METHODS ................................................................................................... 153

ANNEX 5: COMPETITIVENESS CHECK............................................................................................... 161

ANNEX 6: SME CHECK........................................................................................................................... 164

2

Glossary

8EAP 8th Environment Action

Programme

GDP Gross Domestic Product

CAPR Climate Action Progress

Report

GovReg,

Governance

Regulation

Regulation on the Governance of the

Energy Union and Climate Action

C3S Atlas Copernicus Climate

Change Service (C3S)

Climate Atlas

ICT Information and Communication

Technology

CER Climate Emergency

Response

IPCC Intergovernmental Panel on Climate

Change

CDDD Corporate sustainability

due diligence Directive

IPCC AR6 IPCC Sixth Assessment Report

Climate-

ADAPT

European Climate

Adaptation Platform

MFF Multiannual Financial Framework

CAP Common Agricultural

Policy

MREL Monitoring, Reporting, Evaluation,

and Learning

CSRD Corporate Sustainable

Reporting Directive

NAP National Adaptation Plan

DNSH “Do No Significant Harm”

principle

NAS National Adaptation Strategy

ECB European Central Bank NECPs National Energy and Climate Plans

ECDE (viewer) European Climate Data

Explorer

OECD Organisation for Economic Co-

operation and Development

EIA Environmental impact

assessment

PUS Preparedness Union Strategy

EIB European Investment Bank SEA Strategic environmental assessment

EIOPA European Insurance and

Occupational Pensions

Authority

SMEs Small and Medium-sized Enterprises

ESABCC European Scientific

Advisory Board on

Climate Change

TEN-E Trans-European Networks for

Energy

ESRB European Systemic Risk

Board

TEN-T Trans-European Transport Network

EUCRA European Climate Risk

Assessment

TFEU Treaty on the Functioning of the

European Union

GeoRisques Geological and Climate

Risks Portal

UCPM Union Civil Protection Mechanism

3

1 INTRODUCTION: POLITICAL AND LEGAL CONTEXT

Climate change is and will remain the defining challenge of the coming decades and beyond,

shaping societies and economies, requiring significant adjustment to unavoidable impacts. Even though

climate change mitigation policies and measures have been adopted and implemented for decades,

global ambition falls short of what is required to stay within the Paris Agreement temperature

thresholds.1 The delay with which the climate responds to emissions reduction, means that the impacts

of climate change will continue to cause significant damage, in economic, fiscal and human terms, into

the future. The Integrated Framework for Climate Resilience should support the ability of

Member States to tackle these challenges to the benefit of their economies and societies and in doing

so, harmonise and strengthen the preparedness of the European Union (EU). In doing so, it responds

directly to the Political Guidelines for 2024-2029, the political mandate established by the European

Green Deal and the EU Climate Law, complements the adaptation commitments embedded in the Paris

Agreement, and provides a basis for coherent climate risk management across EU and Member States,

sectoral policies, public investment decisions, infrastructure planning and fiscal policy at the scale the

challenge now demands.

The EU has longstanding climate acquis primarily focused on reducing greenhouse gases emissions,

which has driven successful decarbonisation of the EU economy and is aligned with the EU’s

international obligations. The EU will continue these efforts in line with the recently revised European

Climate Law on the 2040 target.2 The current proposal is not in any way an alternative to continued

and redoubled mitigation efforts. This said, scientific evidence suggests that full implementation of

current international mitigation policies would lead to around 2°C of global warming by 2050

and reach 3°C by the end of the century3, resulting probably in 4 to 5°C of average warming in

Europe.4 Preparing for such a scenario is thus necessary tohelp protect businesses and

communities and safeguard our economy and defence capabilities.

Policies dealing with climate risks on the ground need to be strengthened to fill the widening gap

between current low levels of climate resilience and future climate scenarios.5 As this gap widens,

its consequences will be felt more directly across sectors, severely compromising the effectiveness of

sector policies and related investments. Currently, climate resilience and adaptation are addressed in

an incoherent and fragmented manner under several Union policies. In climate-focused policies,

climate resilience is addressed, but only partially and inconsistently, through the European Climate

Law, the Regulation on the Governance of the Energy Union and Climate Action (Governance

Regulation) and the EU Strategy on Adaptation to Climate Change. In sectoral legislation, climate

resilience is implicitly included or mentioned, but in most cases in general terms that are not easily

implementable. For example, consideration of climate scenarios in the national fiscal projects is

mandated, but the methodologies and application are nascent and fragmenting for lack of common

approaches.

1 This commits the Parties collectively to “pursue efforts to remain under 1.5 degrees and not to exceed 2 degrees global

temperature increase above preindustrial levels” 2 This Amendment to the Climate Law introduces a binding interim 2040 target of 90% emissions reduction from the 1990

level. 3 (Calvin et al., 2023) 4 (European Scientific Advisory Board on Climate Change, 2026) 5 (Foster et al., 2026)

4

In 2024, the first European Climate Risk Assessment (EUCRA)6, and the Communication on managing

climate risks7 identified the most urgent climate risks across Europe and concluded that the progress

in integrating climate resilience and adaptation to Union and Member States policies is uneven,

not keeping pace with accelerating climate change, and policy implementation is lagging. The 8th

Environment Action Programme (8EAP) mid-term review8 revealed that the EU and its Member States

must become significantly better at preparing for and effectively addressing climate risks to increase

long-term resilience of the EU economy and society.

More action and a more coherent and systematic integration of climate resilience and

preparedness objectives across EU policies is needed. This has been requested by the European

Parliament,9 the Council of the EU10 and the Committee of the Regions,11 and recommended by the

European Court of Auditors.12 The Environment Council adopted conclusions in December 2025

conveying a strong support to the development of an Integrated Framework for Climate Resilience.13

The Commission, in the latest Climate Action Progress Report (CAPR) stressed how climate resilience

urgently needs to become an integral part of all European policies, as climate change is undermining

Europe’s prosperity, competitiveness and security.14 The information from stakeholders transmitted

during European Climate Pact15 events, the meetings of the Reflection Group for Mobilising Climate

Resilience Financing16, and numerous stakeholder consultations also called for accelerated action and

informed the work on this initiative.

The urgency of building climate resilience and capacity to adapt is underscored by its

interconnectedness with other challenges facing the EU. Climate change is a threat multiplier

exacerbating social tensions, heightening competition over scarce resources and undermining our

security and defence.17 The continent risks severe human, economic, infrastructural and environmental

loss from climate-related impacts which impinge on Europe’s security, society, ecosystems, and the

economy.18 The need for robust climate action and enhanced climate resilience is further reinforced

by the rate of approach towards tipping points19 in the climate system which threaten to unleash high-

risk, irreversible conditions.20 Cascading climate risks can lead to system-wide challenges affecting

whole societies, with vulnerable social groups particularly at risk. These dynamics risk increasing

6 (European Environment Agency, 2024) 7 (European Commission, 2024c) 8 (European Commission, 2024d) 9 (European Parliament 2024/2817) 10 (General Secretariat of the Council, 2024) 11 (European Committee of the Regions (CoR), 2025) 12 (European Court of Auditors, 2024) 13 (Council of the European Union: General Secretariat, 2025) 14 (European Commission. DG CLIMA, 2025a) 15 (European Union, 2026) 16 (European Commission. DG CLIMA, 2025b) 17 (Bilal et al., 2024; European Commission, 2023d; NATO, 2024; World Economic Forum, 2026, p. 1) 18 (European Environment Agency, 2024) 19 critical threshold beyond which a system reorganises, often abruptly and/or irreversibly (IPCC AR6 Glossary definition) 20 Examples include a potential collapse of the West Antarctic ice sheet, leading to extreme sea-level rise, or the breakdown

of the Atlantic Meridional Overturning Circulation (AMOC), which would bring major cooling and harsher winters in

northwestern Europe, threatening agriculture.

5

political and governance instability and fragmentation, both within Europe and in neighbouring regions

to the EU.21

This impact assessment addresses climate resilience within a wider context of external drivers

that determine preparedness. Climate resilience is a part of overall societal and economic resilience

to all relevant hazards, threats and risks (such as global pandemics, social conflict or interstate

aggression, triple planetary crisis22) that may impact on a function or system (e.g. infrastructure, supply

chains, health system, financial system, water supply). Therefore, while climate resilience alone is not

enough to ensure overall resilience, it is an indispensable element thereof. This report is limited in

scope to climatic preparedness and does not duplicate existing work on overall preparedness to all risks

and threats, that are addressed in other initiatives, such as the Preparedness Union Strategy.

Within this wider context, the focus of this impact assessment is on the overall problem of

fragmented and insufficient preparedness for the impacts related to climate change and on

addressing it through the development of a new EU policy framework for strengthening climate

resilience, as a contributor to broader societal and economic resilience. Whilst acknowledging global

interdependencies as an important climate vulnerability factor, the geographical and policy focus of

this initiative is on the EU. Particular attention is nevertheless to be paid to enlargement and

neighbourhood countries in view of the respective policies and as climate risks and impacts are often

shared.

When designing its draft measures and legislative proposals, the Commission shall ensure their

alignment with the objectives of the European Climate Law. As required by Article 6(4), this

impact assessment requires a climate consistency check. The initiative will not directly result in actions

generating greenhouse gas emissions. It will however help minimise the vulnerabilities of climate-

sensitive decarbonisation pathways such as through land carbon sinks and hydropower generation, and

seek to minimise its key external problem driver (see chapter 2 and Figure 1) by encouraging progress

towards climate neutrality. It therefore is deemed consistent with the climate-neutrality objective set

out in Article 2(1) of the European Climate Law and with the Union’s 2030 and 2040 climate targets.

2 PROBLEM DEFINITION

2.1 What is the overall problem and its consequences?

The changing climatic and weather conditions will increasingly undermine Europe’s prosperity,

competitiveness and security. As the planet continues to heat, climate hazards will intensify, bringing

frequent, severe, persistent and far-reaching impacts.

Climate change impacts are a risk multiplier: from mega-droughts leading to water and food

insecurity, unpredictability of wildfires, (marine) heatwaves, disruptions of critical infrastructure and

critical transport routes, to threats to financial markets. Climate impacts continue to cause avoidable

harm, which indicates ‘that existing climate resilience and preparedness across EU and Member States

policies and actions remain insufficient, fragmented, largely incremental, often coming too late,

occasionally incoherent, and are not yet commensurate with the scale, pace and complexity of

21 (European Environment Agency, 2024) 22 (United Nations Framework Convention on Climate Change, 2022)

6

increasing climate risks’23. The current fragmentation of approaches means that poorer regions and

communities will fall further behind economically at an increasing rate; entire categories of impacts

are left unaddressed or underserved; the resilience of transboundary infrastructure and operations is

hampered; the cost of action is higher both in the public and the private sector than need be; and

social and political cohesion is put under further stress.

The level of future risks – and subsequent losses - depends to a large degree on how effectively our

societies and economies manage to reduce their exposure and vulnerability, to enhance preparedness,

and thereby build resilience.

This document uses three related concepts: preparedness, resilience and adaptation. Preparedness is

“the knowledge and capacities developed by governments, response and recovery organizations,

communities and individuals to effectively anticipate, respond to and recover from the impacts of

likely, imminent or current disasters”24. Resilience is defined as “the ability of a system, community

or society exposed to hazards to resist, absorb, accommodate, adapt to, transform and recover from the

effects of a hazard in a timely and efficient manner, including through the preservation and restoration

of its essential basic structures and functions through risk management”25. Climate adaptation is

adjustment in natural or human systems in response to actual or expected climatic stimuli or their

effects, which moderates harm or exploits beneficial opportunities26.

Climate resilience therefore relies on anticipatory, risk-managing, and preventive action that

ultimately leads to higher level of preparedness, and often includes purposeful climate

adaptation.

The findings of EUCRA provide evidence that the EU's current state of preparedness is not

commensurate with the scale, pace or complexity of its climate risks. 21 of 36 major climate risks

identified for Europe require more action and eight of these were assessed as particularly urgent. The

eight most urgent risks span across multiple policy clusters – from ecosystems, food, to health,

infrastructure, economy and finance. The ‘need more action’ and ‘urgent’ indicate the different levels

and/or scopes of addressing the climate risks. For example, coastal wetlands and marine ecosystems

are approaching tipping points, reducing their buffer capacity against severe storms and coastal

erosion. Crop production is hindered by insufficient water retention capacity, multi-year droughts and

soil degradation. Physical assets, such as water management systems, transport networks or energy

grids, are designed around historical climate averages rather than future extreme events and usually do

not take into account compound risks, such as simultaneous heatwaves and droughts reducing thermal

cooling capacity or grid stability. EUCRA also identifies risks to public finances, property and

insurance markets and European solidarity mechanisms, with the latter already at critical levels and

requiring urgent action,

The Member States exposure to climate risks and levels of preparedness are not uniform.

EUCRA shows that southern Europe will face stronger climatic pressures than the rest of Europe, as

will Arctic areas. The outermost regions have a distinct set of risks. Asymmetrical exposure to climate

impacts exacerbates the already existing disparities between regions in terms of need for climate

adaptation, risk prevention and preparedness, which can put pressure on EU-wide cohesion. The

23 (European Scientific Advisory Board on Climate Change, 2026) 24 (United Nations Office for Disaster Risk Reduction, 2017a) 25 (United Nations Office for Disaster Risk Reduction, 2017b) 26 (Intergovernmental Panel on Climate Change, 2001)

7

Member States follow different approaches when preparing national adaptation strategies and plans,

with only some of them based on robust, comprehensive climate risk assessments. Moreover, the report

on progress on implementation of Article 6 of the Union Civil Protection Mechanism27 shows that

Member States see different risks as key ones. This also means that the fiscal impacts from increased

global warming will vary across countries (more details in Annex 8 – Fiscal impacts)28.

Regarding past events, the data on economic losses and fatalities caused by weather- and climate-

related extreme events shows a high degree of divergence among the Member States. While in

absolute terms, the highest economic losses during the period 1980-2024 were recorded in Germany,

Italy, France and Spain, the highest losses per capita were calculated in Slovenia, Luxembourg and

Spain.29 The highest losses per area (in km2) were found in Slovenia, Belgium, Luxembourg and

Germany30.

According to the latest EEA data31 440,000 fatalities from climate-related events were reported

between 1980 and 2024, most of which were caused by heatwaves, cold waves, droughts and forest

fires. While the heatwaves caused the highest number of fatalities, the distribution between event types

and how they take place over time vary significantly across different countries. The 30-year moving

average indicates an upward trend of the economic losses (see Annex 8), proving the vulnerabilities

and exposures have not been lowered at a pace that can counter the increase in hazards.

All of the above shows that the current overall level of preparedness for climate risks is clearly

inadequate. Differences in climate-related losses and fatalities between Member States reveal gaps

in climate risks management and uneven levels of preparedness. The different levels of severity

and urgency of climate risks addressed in EUCRA points to an overall trend for further

fragmentation in preparedness of the European economy and society to climate risks. As many

climate risks affecting Europe are shared or transboundary in nature, such as risks to river basins and

other ecosystems, energy and transport systems, supply chains and financial systems, this

fragmentation ultimately reinforces the systemic nature of climate risks.

Therefore, the fragmented, uneven and insufficient preparedness of the European economy and

society for climate change impacts is the overall problem which must be addressed.

Consequences of the overall problem

Economic consequences32

Fragmented and insufficient preparedness for climate impacts have already severe economy-

wide consequences. Furthermore, it leaves underserved or unaddressed entire categories of

impacts that require coordinated response at a higher level, such as ensuring that roads and railways

withstand higher levels of maximum temperatures than previously experienced, transitioning food

systems to ensure production and access under much more extreme weather, or flood protection for

unprecedented levels of floods. It hampers the resilience of transboundary infrastructure and

27 (COM(2024) 130 final) 28 (European Commission, DG ECFIN, 2026; European Commission. DG ECFIN and Gagliardi, N. (2025). 29 (European Environment Agency, 2025a) 30 (European Environment Agency, 2025a) 31 (European Environment Agency, 2025a) 32 See also Annex 8 for more details

8

operations, since territories are making their own individual assumptions about the level of impacts

to prepare for.

If not properly addressed, serious sector- and regional-specific risks to Europe could catalyse a

systemic financial shock, and trigger economy-wide failures33.

EU-wide economic losses from weather- and climate-related extremes have risen significantly in

recent years. More than one quarter of the EUR 822 billion of damage registered between 1980 and

2024 occurred after 2021.34 In 2024, flooding alone caused EUR 31.1 billion in losses across the EU35.

Annual losses from droughts are amounting to EUR 9 billion a year and are spread unevenly across

Member States, with Spain (EUR 1.5 billion/year), Italy (EUR 1.4 billion/year) and France (EUR 1.2

billion/year) suffering the greatest losses36. A single event can result in severe consequences, for

example reconstruction costs of the 2023 flash flood damage in Slovenia were estimated to represent

16% of their annual national GDP37. Simultaneously, extreme events are decreasing economic activity.

Preliminary results suggest that in 2025 the gross value added in Europe was lowered by EUR 43

billion due to extreme events (floods, droughts, heatwaves), while these losses occurred

disproportionally in Southern Europe38. Furthermore, economic losses are often long-lasting with

indirect effects and productivity losses that can compound and intensify with time -, these losses could

rise to EUR 129 billion by 202939.

Estimates of future climate-related GDP loss vary significantly across the literature, depending

on the modelling approach. 40 A report on the costs of inaction prepared for the Commission estimates

that GDP losses in the EU could be up to 1% annually in the coming years, 2.3% by 2050, and up to

7% by the end of the century41. Others estimate that by 2050, climate change could reduce average

GDP per capita by 3–15% due to rises in local temperatures and sea-level, and some climate tipping

points, based on a rise in global average temperature of 2.2–2.8°C relative to the pre-industrial climate,

and assuming no further increases in adaptation and resilience42. Yet another study says that current

climate trends could lead to a loss of EUR 2.4 trillion between 2031 and 205043 while food prices could

be 20% higher by 2050.

The costs depend on the type of events considered, and on whether and how compounding effects

across risks are accounted for. Furthermore, they are highly unevenly distributed across Member

States. Under a sustainability scenario, direct annual coastal flood losses for Europe by 2100 are

projected to grow to EUR 209.8 billion (very likely range: EUR 29.7 billion to EUR 844.5 billion).

33 (European Environment Agency, 2024) 34 (European Environment Agency, 2025b) 35 (European Scientific Advisory Board on Climate Change, 2026) 36 (European Commission. Joint Research Centre., 2020d) 37 (Republic of Slovenia - Ministry of Cohesion and Regional Development, 2023; World Bank Group, 2026) 38 (Usman et al., 2025)

39 (European Scientific Advisory Board on Climate Change, 2026) 40 Structural models that aggregate losses across specific sectors typically project lower global GDP impacts of 1% to 5%

at 3°C of warming. In contrast, macro-statistical models, which capture historical sensitivities of productivity to

temperature, project far more severe systemic shocks with losses potentially exceeding 20% (Bilal et al., 2024). While

structural models offer causal clarity but often omit non-market and compounding risks, macro-statistical approaches

attempt to capture broader systemic vulnerabilities yet fail to account for complex spatial correlations in economic data. 41 (European Environment Agency, 2025b) 42 (Rising et al., 2026) 43 (European Commission. Directorate General for Economic and Financial Affairs., 2025)

9

Under a scenario with fossil fuel-based development, the losses would rise to EUR 1,268.4 billion

(160.9–4,731.1); France, the UK, Italy and Denmark would experience the highest absolute increase

in damages, and the countries with the highest loss as share of GDP would be Cyprus, Greece,

Denmark, Ireland and Croatia44. Absolute annual drought losses for the EU under a 3-4℃ warming

scenario are projected to increase five-fold, rising to EUR 45 billion per year by 210045. The

Mediterranean and Atlantic regions are expected to suffer 86% of total European losses46.

The costs of adaptation do not rise linearly with temperature but increase significantly faster.

For the EU and UK, annual adaptation investment needs are estimated to double when moving from

1.5°C to 2°C and roughly quadruple at 3-4°C of warming47. Keeping in mind the evolution of the

global warming trajectory, the sooner the EU and Member States adapt and prepare, the more solutions

there are and at relatively lower cost. The uncertainties regarding the climate impacts are significantly

higher with high emission scenarios, increasing the risk of facing unmanageable situations48.

Climate impacts will affect all economic sectors. Climate hazard exposure across a sample of 70

investment grade European companies is projected to rise about 23% between the 2020s and the

2050s.49 50 A 2025 TRACE paper51 indicates projected annual damages in Europe by 2050 under

different warming pathways (see Table 1).

Table 1: Sectoral climate related losses indicating relative impact (EUR billion, per year) 52

Sector 1.5°C 2°C 3°C

Labour 35 44 71

Residential 28 31 39

Industry & Commerce 27 31 40

Agriculture 11 13 17

Ecosystems 6 7 7

Transport 4 5 10

Energy 3 3 4

The climate impacts and risks reduce productivity, depress growth, and undermine fiscal

sustainability and heighten financial stability risks e.g.through increased potential credit defaults,

rising insurance premiums, and impacts on house values.53 According to CDP, a non-profit that runs

an independent environmental disclosure system, companies reported that extreme-weather events

caused nearly EUR 2.6 billion in real losses in 2025 alone, primarily through increased direct costs

(EUR 266 million) and operational shutdowns (EUR 230 million). Heavy rain was the largest single

driver of these losses, accounting for EUR 1.3 billion across disclosing companies54.

44 (Vousdoukas et al., 2020) 45 (European Commission. Joint Research Centre., 2020c, 2020e) 46 (European Commission. Joint Research Centre., 2020c) 47 (European Environment Agency et al., 2025)

48 (European Environment Agency et al., 2025) 49 (S&P Global, 2026) 50 (European Commission. Joint Research Centre., 2025a; European Foundation for the Improvement of Living and

Working Conditions., 2025a) 51 (Feyen, 2025) 52(Feyen, 2025) 53 (European Commission. DG ECFIN (2025); European Environment Agency, 2024; U.S. Senate Committee on the

Budget, 2024) 54 (CDP, 2026)

10

Looking ahead, however, the figures will escalate, with companies anticipating EUR 773 billion in

future financial impacts over next 10 years, which are expected to be driven by reduced production

capacity (EUR 280 billion) and asset impairment or early retirement (EUR 188 billion). The losses are

expected to spread across systems that businesses depend upon, such as infrastructure, supply chains,

insurance markets and public services55. These impacts often do not remain within the country

primarily affected, but propagate through trade, supply chains, increased prices and volatility, as well

as subsequent socio-economic tension which can cascade effects across boundaries, and are

increasingly recognised as a systemic risk for the EU’s short- and long-term security and prosperity.56

The indirect impacts cause additional heterogeneity in exposure to climate change risks: some

countries are directly affected by climate change (e.g. Mediterranean countries) while others

experience high exposure due to their large trade connections, such as Germany and Luxemburg.57

Weak private sector resilience reduces the EU’s competitiveness and the functioning of the single

market, raising production costs, deterring investment, and slowing climate resilient innovation and

business models. Annual climate-related economic losses in the EU have averaged EUR 45 billion

since 2020. Climate hazard exposure across a sample of 70 investment-grade European companies is

projected to rise by 23% from the 2020s to the 2050s.58 These are burdens on productivity, return on

investment and fiscal headroom. Without stronger policy coordination, the EU will struggle to manage

rising risks or seize economic opportunities.59 It is widely recognised that climate resilience holds

strong innovation opportunities representing major future markets globally60, but lack of

experimentation and upscaling, limited understanding of future markets and insufficient policy

coordination hamper the development of a climate adaptation economy61.

Delays in managing climate risks and in raising preparedness levels across the EU will likely

increase costs, deepen disruptions, and leave the EU economy and industry losing ground to

global competitors, especially those that innovate and invest in climate resilience.

Defence and Security Consequences

The Joint Communication on the Climate-Security Nexus in 2023 already recognised62 that the

impacts of climate change and lack of preparedness are intensifying and destabilising the

security situation for Europe. This is further affirmed in the forthcoming Comprehensive Risk and

Threat Assessment.

Three events in the period 2022–2024 alone illustrate climate impacts on European defence: extreme

heat disrupted military training operations across Europe in 2022; in 2023, a wildfire reached a major

Hellenic Air Force base and ignited a munitions stockpile; and in 2024, the Valencia floods triggered

the largest peacetime deployment of the Spanish Army in an operation. The last one also demonstrated

that hostile actors are systematically exploiting climate disasters to spread disinformation and erode

55 (CDP, 2026) 56 (Auer et al., 2025; Clark et al., 2025; Council of the European Union. European External Action Service, 2021; Harris

et al., 2026; Knaepen et al., 2022; West et al., 2021) 57 (European Central Bank., 2024b) 58 (S&P Global, 2026) 59 (European Central Bank., 2024a; European Investment Bank, 2024) 60 (SYSTEMIQ, 2026) 61 (European Commission. Joint Research Centre., 2024; European Commission. Joint Research Centre et al., 2026) 62 (JOIN(2023) 19 final)

11

public trust in governments. Even beyond specific disasters, structural risks are becoming more

entrenched.

These events expose a deeper structural vulnerability: EU military installations depend almost

entirely on civilian-owned critical energy infrastructure for electricity, fuel, gas and water, yet

defence ministries have limited control over the resilience of such infrastructure to climate impacts.

When civilian energy networks fail, the cascade to military readiness is direct - a study found that

military installations experienced 3,018 unplanned utility outages in a single year, with severe weather

responsible for a quarter of prolonged outages.63 It also identified a critical gap that persists across EU

Member States: climate hazards are not yet systematically integrated into defence capability planning,

procurement criteria or investment lifecycles. Environmental and climate vulnerability can also be

exploited by adversaries: Russia's destruction of the Kakhovka Dam displays how a deliberate action

can exploit the devastation nexus of environmental and infrastructure warfare, while the broader

destruction of climate and energy infrastructure in Ukraine demonstrate that adversarial actors have

already operationalised climate vulnerability as a weapon.

Europe is also materially exposed to climate risks through its supply chains. The continent's

defence industrial base depends on materials and products transported through maritime chokepoints

increasingly vulnerable to climate disruptions. The closure of the Straits of Hormuz and the threat of

extreme El Niño conditions with consequent impacts on food security in the developing world illustrate

how climate and geopolitical supply chain risks cascade and amplify each other. Impacts of climate

change, both extreme weather events and gradual climatic changes, can have cascading effects that

cross borders and continents. The effects can further cascade and escalate through political and security

relations, international trade, supply chains, financial markets, international aid as well as migration.

The European neighbourhood, with a large overlap of pre-existing fragility and climate vulnerability,

could see further escalation with conflict and migratory spill-over effects into Europe. European

companies with assets and operations in affected areas may see shocks influence capital flows, profit

margins and insurance premiums, with potential knock-on effects for the banking sector and national

economies. With their potential to lead to far reaching and unforeseen effects – potentially affecting

political and social stability worldwide, these transboundary risks have been increasingly recognised

as a systemic risk for the EU endangering its security and prosperity in the short and long run.

Social consequences

Insufficient and fragmented climate preparedness has very negative impacts on people and

society. More than eight out of ten Europeans consider climate change a serious problem, and four out

of five experienced at least one climate-related impact in the last five years.64 As climate risks intensify,

the social consequences of inaction can negatively affect employment, housing security or public

health in Europe.65 In 2022 in the EU, more than 60,000 people died prematurely because of the

summer heatwave. In Portugal, heatwaves have increased hospitalisations across all age groups and

major disease diagnostic categories by 19%.66 Labour productivity losses due to stress have also

negative effects on the economy.67 By the end of the century, in the EU and the UK 100 million people

63 (European Commission. Joint Research Centre., 2023) 64 (European Environment Agency et al., 2026) 65 The European Climate and Health Observatory provides a comprehensive overview. 66 (Alho et al., 2024) 67 (European Commission. Joint Research Centre., 2025a; European Foundation for the Improvement of Living and

Working Conditions., 2025b)

12

are expected to experience extreme heatwaves every year, and extreme heat-related mortality in the

EU is projected to increase more than 30-fold at 3°C global warming levels. 68

Climate impacts and risks disproportionally affect vulnerable groups, such as low-income

households, elderly people, pregnant women, children, people with disabilities, workers at poorly

climate-controlled workplaces, migrants and ethnic minorities. The level of climate vulnerability

depends on socioeconomic and other environmental risk factors (income, health, gender, age, exposure

to pollution etc.) which often overlap. Multiple exposures and recurrent climate shocks may thus trap

already vulnerable populations in a downward spiral of worsening impacts, poverty, displacement and

reduced access to essential services.69 These groups not only have limited ability to prepare for climate

impacts, but also to respond and recover from them. One example are immigrants who often do not

have stable housing and/or limited local language knowledge that directly compromises their capacity

to understand and respond to early warning notifications of climate events. Workers in outdoor

occupations (e.g. agriculture, fisheries, construction) and those performing physical work in indoor

environments that are not or poorly climate-controlled are particularly exposed to climate impacts.

Emergency workers (e.g. firefighters, rescue services) and healthcare workers can be overburdened

during or after climate emergencies.70

Climate impacts exacerbate inequalities and conflicts, erode social cohesion and fray trust. For

instance, water shortages can trigger regional conflicts. The related crop failures, declining fish stocks,

less snowfall in winter tourism resorts and other disruptive changes undermine regional livelihoods.

The heatwaves also increase online hate speech71 and gender-based violence.72

Failing to implement climate resilience in a transparent and just manner may also generate

tensions across regions and generations, since measures implemented without considering

distributional effects can shift risks from one community or territory to another, burdening vulnerable

groups.73 It is therefore of utmost importance that climate resilience is considered from a just resilience

perspective.

Just resilience is a set of policies, measures, and guiding principles intended to tackle systemic

inequalities in the transition towards a climate-resilient society, in line with the principles of the

European Pillar of Social Rights. (More details in Annex 11)

Environmental consequences

The environmental consequences of insufficient and fragmented preparedness in EU and Member

States are evident – Europe’s ecosystems are experiencing intensifying pressure, and climate change

has already been driving irreversible losses, jeopardising the delivery of vital ecosystem services

for Europe’s economy and population. Ecosystems on up to half of Europe’s land area may

experience major climate-change shifts during this century, including many of today’s protected

areas.74 Climate change exacerbates the rate and magnitude of several ongoing land degradation

68 (Naumann et al., 2020. EUCRA 2024) 69 (European Scientific Advisory Board on Climate Change, 2026) 70 (European Agency for Safety and Health at Work, n.d.) 71 (Dave Jones, 2025; Stechemesser et al., 2021) 72 (Mulambo et al., 2025) 73 (European Scientific Advisory Board on Climate Change, 2026) 74 (Hoffmann et al., 2019)

13

processes, introduces new degradation patterns, and is already the dominant driver of coastal erosion,

permafrost thawing, and emergence of wildfires.75

Fragmentation of preparedness for climate impacts can lead to a large-scale disruption of

biodiversity and ecosystem services. Such disruption of ecosystem services could critically impact

the existing water cycle, food production and infrastructure - with repercussions on carbon sinks,

human health and economic activities, which may further trigger other changes.

Other factors affecting ecosystems include land use planning and, particularly, land use management,

deforestation, biodiversity loss, land degradation and unsustainable practices like excessive water use

and intensive farming, which negatively affect soil health and water quality and quantity.76 To provide

but a few examples: droughts, heatwaves and wildfires have caused unprecedented tree mortality and

damage in Europe’s forests in recent years, with more than 60% of EU forest biomass exposed to

future risks77, and without effective countermeasures, the value of forest land may decreaseby

14 to 50% by 210078 . Droughts negatively affect the adaptative capacity of agricultural ecosystems,

the resilience of forest ecosystems and in urban ecosystems droughts indirectly affect the ability of

green urban spaces to protect people against heatwaves.79 Oceans are projected to enter ‘unprecedented

conditions’ over this century, marked by marine heatwaves, acidification and relative oxygen loss80

that further lead to faster loss of biodiversity, habitats and productivity.

75 (Intergovernmental Panel On Climate Change, 2022a) 76 (European Environment Agency, 2024) 77 (Forzieri et al., 2021) 78 (Hanewinkel et al., 2013) 79 (European Environment Agency, 2025c) 80 (Intergovernmental Panel On Climate Change, 2022b)

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Figure 1: Problem tree81

81 The problem definition phase of this impact assessment considered initially a wide array of drivers and problems,

including many external drivers, as shown and described in supporting report. The problem tree displayed here centres on

the drivers and problems which this initiative addresses.

15

2.2 What are the key problems addressed by this policy initiative?

The overall problem can be broken down into three main elements: fragmented climate resilience in

EU and Member States (P1), and the unpreparedness of the private sector (P2) and of the population

(P3).

2.2.1 Problem 1: Fragmented climate resilience in EU and Member States

Building resilience and enhancing preparedness for climate risks requires combined and coordinated

efforts by actors across policy domains and at multiple levels of governance, including national and

subnational, in order to put in place the enabling conditions for adaptation such as adequate policies,

resources, and institutional capacities for coordinated systemic responses.

At the moment, EU and Member States lack a common reference for future climate conditions and

a unified vision of how Europe’s climate resilience must be built. This absence of a coherent

Europe-wide understanding of climate risks and preparedness needs is a structural deficiency of the

existing legal framework rather than a failure of individual actors. (more details in section 2.3)

Weak consideration of climate preparedness in policy- and decision-making, poor coordination in

implementation, and inadequate monitoring hinder progress on the collective ability to manage

escalating climate risks effectively. The EUCRA confirmed that the “complicated and at times

ambiguous configuration of risk ownership presents a serious challenge for the implementation of

robust and effective adaptation measures”82.The EUCRA policy readiness assessment rates the

preparedness of EU policies to manage specific climate risks as 'medium', defined as ”limited

consideration of climate hazards, short-term focus, lack of proactive actions, or a lack of clear targets”

confirming that existing instruments are not calibrated to manage those risks at the level required by

projected climate change trajectories.83 This reflects systemic inadequacy.

Whilst virtually all major EU policy sectors are exposed to specific climate impacts and risks, there

are also significant discrepancies and fault lines between how these various sector policies

consider and implement climate preparedness and resilience. A document-based analysis of a

sample of 40 EU policy instruments in six sectors (see Annex 10) shows major gaps and significant

differences in scope, objectives, climate projections used, responsibilities, planning, and monitoring

approaches. This suboptimal, checkered picture does not only point to risks in each policy sector

individually, such as potential water, agricultural production and food, energy supply or transport

disruptions during extreme weather events. The identified inter-sector fragmentation also increases the

risk of cascading impacts across social, economic, and ecological domains.

There are persistent gaps in the availability of data, institutional capacity and financial resources,

which further contribute to differences across Member States. Gaps are particularly relevant for

the assessment of compound and cascading risks, which remain less systematically addressed. These

limitations, in turn affect how climate risks are identified and integrated into policies. It contributes to

uneven levels of risk awareness, preparedness and policy uptake across countries and sectors.84

The fragmentation of climate resilience and preparedness across EU can be illustrated by an

example. According to the EEA, the 2003 European heatwaves caused approximately 18,000 excess

82 (European Environment Agency, 2024) 83 (European Environment Agency, 2024) 84 (European Environment Agency, 2026b)

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deaths in France alone.85 In reaction to this excess mortality and to mitigate the impact of future

heatwaves, French authorities bolstered their national resilience frameworks, including heat health

action plans, public health preparedness measures, and urban adaptation investment. As a result,

similar heatwaves in 2022 had comparatively minimal effects in France with 7,000 excess deaths. In

Italy, heat health action plans exist in some regions but are not uniformly mandated across all

municipalities. The summer of 2022 also resulted in an estimated 18,000 excess deaths from heat in

Italy, despite access to the same scientific evidence, the same climate projections, and the same

voluntary EU-level guidance as in France. This shows that other countries which had not adopted

proactive measures like France remained acutely vulnerable. Where no binding requirement exists to

establish and activate heat preparedness protocols, implementation is uneven, under-resourced, and

dependent on local discretion.

This example demonstrates that effective and common legal and policy frameworks can yield

substantial and quantifiable benefits. However, at the same time it shows the insufficiency of a reactive

and fragmented approach, which results in overall avoidable losses and increased disparities between

Member States.

Policy approaches vary due to different governance systems, legal traditions, institutional

arrangements and coordination mechanisms. Climate risk evidence is often not clearly linked to

measurable policy objectives, corresponding indicators or climate-risk responsive actions, reducing

the ability of planning systems to guide action and track progress. Diverse policy approaches and

complex coordination during preparation and implementation of climate adaptation policies across

sectors and governance levels continue to hinder effective implementation and policy coherence across

Europe.86

Another example of the consequences of fragmented policy approach is the catastrophic flooding of

the Ahr valley in Germany in 2021, which caused over 180 deaths and approximately EUR 33 billion

in economic damage. Germany operates under the EU Floods Directive, which requires flood hazard

maps and risk management plans. Those instruments were formally in place. However, the Floods

Directive does not require risk management plans to be calibrated to forward-looking climate

projections, nor does it establish binding requirements for the integration of updated hazard data into

spatial planning and building regulations at the local level. German authorities had complied with the

letter of the existing legal framework. The absence of a legal requirement compelling the revision of

risk assumptions in line with changing climate conditions was a key factor for the Ahr disaster. While

acting in compliance with the existing European legal framework, Germany was insufficiently

prepared to prevent catastrophic outcomes, as it lacked a forward-looking obligation.

Finally, regional and local implementation is hindered by the limited capacity and resources

available to subnational authorities. This impedes the ability to translate national priorities into targeted

action.

In conclusion the preparedness and resilience building in the EU and Member States is

fragmented and does not protect the economies and societies to the extent necessary to face current

and future climate risks.

85 (European Environment Agency, 2025b) 86 (European Environment Agency, 2026b)

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2.2.2 Problem 2: Unprepared private sector - Insufficient climate risk awareness/perception and

preparedness among businesses

For this problem, the private sector includes large corporations, SMEs, primary and land-based sectors

(including farms, forestry enterprises and businesses in food processing and rural tourism that depend

on the climate-sensitive resources); financial actors (including banks, insurers, institutional investors

and other intermediaries, insofar as they manage and price physical climate risks.

The private sector is not immune to the negative impact of extreme weather events. The share of firms

experiencing two or more heatwaves annually rose from 10% in 2000 to over 40% by 2021 across a

sample of 23 countries.87 Heatwaves significantly reduce labour productivity and could reduce global

working hours by the equivalent of 80 million full-time jobs by 2030, with the most pronounced

impacts in agriculture, construction, transport, and tourism88.

Business losses have ripple effects across the broader economy. Physical damage to business assets

and disruptions in production cascade through value chains and thereby lead to higher input costs,

reduced productivity and forgone revenues. An example of these ripple effects is the slowing of

shipping traffic along the Rhine River during the 2018 drought, when water levels fell so low that

cargo ships could carry only a fraction of their normal loads. As a result, transportation costs increased

and supply chains were disrupted, leading to a 1% reduction in Germany’s manufacturing output89 and

a 10% reduction in the production of chemicals and pharmaceuticals over three months90.

Therefore, it is of utmost importance that businesses reduce their vulnerabilities to climate impacts.

However, adaptation gaps are widespread among businesses, with many firms still responding

reactively to climate impacts rather than taking anticipatory and impactful measures91, and climate

resilience and adaptation planning remaining ‘nascent’ in leading European companies.92

SMEs are particularly affected due to limited access to finance, data and risk management capacity.93

Inconsistent public risk data, unclear policies, and fragmented guidance create high uncertainty and

discourage investment, especially for cross-border businesses.94 The high upfront costs of adaptation

also act as a barrier to action: adaptation is seen as a cost rather than an investment. While adaptation

investments tend to yield results over the medium to long term, this may not align with shorter business

planning cycles. At the same time, markets still underprice climate risks, risking financial and fiscal

instability95 and disruptions in interconnected sectors, forcing costly public interventions when failures

cascade across borders.96 Financial institutions only partially account for physical risks in lending and

most disaster losses remain uninsured.97

87 (Costa et al., 2024) 88 (Costa et al., 2024) 89 (Deutsche Bank, 2023) 90 (OECD, 2023) 91 (Intergovernmental Panel On Climate Change, 2023) 92 (S&P Global, 2026) 93 (European Investment Bank, 2024; OECD, 2023) 94 (European Commission. DG FISMA et al., 2020; OECD, 2024c) 95 (European Central Bank., 2021) 96 (ABN-AMRO, 2023) 97 (European Central Bank et al., 2024)

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2.2.3 Problem 3: Unprepared population - Insufficient climate risk awareness/perception and

preparedness among the EU population

For this problem populations are understood as households and citizens.

While many EU citizens are aware of climate change, affected by it and concerned about the impacts,

most remain underprepared and household-level measures remain inadequate 98. Climate resilience is

a shared responsibility: public authorities must provide policies and emergency support, businesses

should manage operational risks, and individuals act within their household, family and local

community.

The risks associated with climate extremes are directly linked to society’s vulnerability to them, with

demographic shifts and socioeconomic transformations altering future exposure to these extremes. The

complex interplay between climate change and population dynamics can profoundly influence the

exposure and vulnerability of communities to such extremes and makes the case for better

preparedness even stronger.

EUCRA99 concluded that societal preparedness remains low, as policy implementation is lagging

substantially behind quickly increasing risk levels. Preparedness fragmentation, combined with private

sector unpreparedness, weakens the population’s structural ability and incentives to act. Capacity for

resilience is also unevenly distributed, with vulnerable groups having fewer resources for it.100

Behavioural hurdles, such as short-term thinking or over-reliance on public support, or simply feeling

overwhelmed by the scale of challenge, further reduce individual action.

2.3 What are the problem drivers?

2.3.1 Institutional, policy and governance barriers

Institutions, governance structures and public policy responses influence, to a large degree, the levels

of exposure and vulnerability to the growing climate hazards, shaping the climate related risks for the

European economy and society.

2.3.1.1 Policies not reflecting future climatic conditions

Chapters 1 and 2.1 have already described the effects of climate change, and Annex 12 provides more

detail on the projected future climates. To recapitulate these briefly: Europe is currently on course to

be 3.2°C to 4.5°C warmer than in pre-industrial times, which will result in more frequent and more

severe hazards, both from slow-onset processes and extreme weather events.

One of the primary drivers of uneven climate resilience and preparedness across the Union is that the

policies do not reflect future climatic conditions. The provisions are set for the climate of today/time

of adoption and while policies often have long-term consequences and sometimes significant lag

98 (European Commission. DG ECHO, 2024; European Environment Agency et al., 2026) 99 (European Environment Agency, 2024) 100 (European Environment Agency., 2025)

19

before they bring effects, they do not consider sufficiently the climatic conditions in which the policies

will need to keep being effective.

Generally, projected climatic conditions are insufficiently reflected in EU sector policy

requirements, if at all (see Annex 10). As a result, decisions taken today (e.g. on infrastructure design,

building standards, land-use planning, and water management) lock in vulnerability to projected

climate hazards for the lifetime of those systems. This represents a systemic preparedness failure.

Given the long lead times associated with adaptation action and the multi-decadal policy horizons

involved, the absence of legally binding requirements to calibrate decisions to future climatic

conditions is a compounding failure. Its consequences grow with each investment cycle in which it

remains unaddressed.

This driver applies and contributes to all three problems identified above.

2.3.1.2 Unclear, overlapping, incomplete climate resilience governance at EU and Member State

levels

Unclear governance structures and administrative barriers – such as incoherent or missing laws

and procedural requirements, institutional silos or lack of institutional capacity – can result in gaps,

overlaps and inconsistencies between sector policies or administrative levels101, thereby

preventing a systemic, efficient and effective response to climate risks and affecting the potential for

transformational adaptation. Weak coordination, lack of understanding of climate conditions, common

objectives and goals, and divergent horizontal climate resilience policy and sector approaches can lead

to weak, inconsistent or contradictory outcomes, and dampen the signals and incentives needed by

investors.102

At Union level, the current horizontal climate resilience governance framework combines binding and

non-binding policy instruments (see Annex 10). The legally binding European Climate Law and

Governance Regulation are complemented by the EU Strategy on Adaptation to Climate Change

established under the Climate Law as a Communication, intermediate policy messages presented in

the Commission Communication on managing climate risks, and with ad hoc knowledge products such

as the Commission guidelines on Member States’ national adaptation strategies and plans and EUCRA.

The EU Strategy on Adaptation to Climate Change is a non-binding instrumentthat sets out the

Union vision to become a climate-resilient society by 2050. The original strategy dates from 2013

and was revised in 2021 to consider the Paris Agreement’s temperature goal of 1.5°C; it puts forward

a multitude of actions for the Commission.

However, since the adoption of the Adaptation Strategy, climate projections for Europe have evolved

significantly (indicating stronger warming) and the first EUCRA has been published. The Strategy’s

non-binding nature means that it cannot create enforceable obligations on the Union and the Member

States, resulting in incoherent and fragmented approaches. As highlighted by the first Union level

progress assessment the Strategy has not delivered measurable and sufficiently rapid climate resilience

outcomes, with several envisaged actions still to advance.103 The Strategy does not constitute a solid

101 (European Court of Auditors, 2024; van Minnen et al., 2025) 102 ‘Fragmentation and lack of policy coordination’ and ‘regulatory uncertainty and inconsistent policy signal’ were also

frequently highlighted as a key barriers to better climate preparedness in the OPC. 103 (European Commission. DG CLIMA, 2025a)

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overall framework due to its aspirational nature and the fact that it is based on outdated

assumptions. (More details in Annex 10)

The European Climate Law is a regulation establishing the main legal foundation for horizontal

climate adaptation action at Union and Member State level, with limited links to sectoral policies.

It merely sets out a general obligation to ensure ‘continuous progress in enhancing adaptive capacity,

strengthening resilience and reducing vulnerability to climate change’, in accordance with the Paris

Agreement. It requires the Commission to adopt and regularly review the Union adaptation strategy,

and Member States to adopt and review national adaptation strategies and plans, based on robust

climate change and vulnerability analyses, progress assessments and indicators. The Law contains

provisions for five-yearly assessments by the Commission of Union progress and measures, and of

national measures.

However, the Law’s adaptation provisions are too general and lack clear specific objectives or targets,

adaptation-specific governance and robust progress assessment, which limits systematic consideration

of climate risks in Union sectoral policies and across Member States. While the Law creates a general

obligation to pursue climate adaptation, it does not provide a sufficiently comprehensive and

operational framework to ensure coherent and effective climate resilience action across the

Union. (More details in Annex 10)

The Governance Regulation provides the Union framework for planning and reporting on

energy and climate policies and targets. It requires Member States to set out their planned policies

and measures in integrated national energy and climate plans (NECPs), and report regularly on their

progress. As regards adaptation, it requires adaptation goals to be reflected in NECPs “where

applicable” and sets the reporting channel through which Member States provide information on

horizontal national adaptation actions, and on some sectoral actions.

However, the Governance Regulation has not been sufficient to support the level of climate

resilience needed across the Union and Member States. The 2024 Commission report on the review

of the Governance Regulation104 and the 2025 EU-wide assessment of the final updated NECPs105

confirm that adaptation remains insufficiently embedded: NECPs often refer to national adaptation

strategies and plans rather than systematically integrate climate risks considerations into energy sector

and climate planning; and gaps and inconsistencies persist in the scope and quality of information

reported under Article 19(1), and adaptation reporting lacks indicators to track progress. (More details

in Annex 10)

While the Union-level horizontal policy framework sets broad aspirations and provides some tools,

both its level of detail and its practical application remain insufficient. The ECA concluded106 that

reporting on climate adaptation adds limited value for tracking progress and supporting future policy

decisions, due to the lack of common indicators, identified challenges in tracking adaptation related

funding, and weaknesses in the use of scientific data in national adaptation policies, in particular with

respect to sectoral policies.

104 (COM(2024) 550 final) 105 (European Commission, 2025b) 106 (European Court of Auditors, 2024)

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In the last decade, Member States have been gradually strengthening their policy foundations

for climate resilience and adaptation. The latest data107 108 shows that all 27 Member States have

adopted national adaptation policies, and most have completed at least one full policy cycle. However,

progress remains uneven in terms of climate risk evidence base, legal anchoring, policy formats and

progress monitoring.

21 Member States have published climate change and vulnerability analyses, although methodological

approaches vary. Six of these analyses are more than eight years old, which limit their ability to reflect

the latest climate science and evolving risk patterns. 14 Member States anchor climate adaptation in

national climate legislation, but the scope and level of detail of these provisions differ. In addition, 14

Member States use national indicators to track implementation progress, but these indicator

frameworks are different and cannot provide a consistent basis for assessing adaptation progress across

the Union.

These individual policies do not a guarantee of implementation and systematic operational

preparedness across the Union and across national borders. The policy development continues to

be challenged by diverse approaches, complex coordination across sectors and governance levels,

unclear ownership of climate-related risks, variable institutional capacity and uncertain financing. The

fragmented Member States’ approaches continue to affect also the implementation of measures and

challenge policy coherence. Although the subnational level is central to adaptation, regional and local

implementation remains constrained by limited capacity and resources, limiting the translation of

national priorities into targeted action and contributing to uneven preparedness across Europe.109

The Commission assessment of Member States’ adaptation progress under the European

Climate Law110 showed that, while national climate adaptation frameworks were in place, major

weaknesses remained in their operationalisation and implementation. Overall, key gaps concerned

insufficient climate risk and investment needs assessments, lack of dedicated budgets, use of outdated

scientific data, weak interinstitutional coordination and integration of nature-based solutions in

strategic and sectoral policies, and missing indicators for monitoring of actions and results. Due to lack

of harmonised approaches under the Law across all steps of the climate adaptation policy cycle, the

Commission was unable to assess the real progress on the ground towards enhanced climate

preparedness and resilience. Instead, the assessment focused on processes and administrative

arrangements. For the same reason, the Commission could not assess relative progress at Member State

level nor could have it aggregated in a meaningful manner. These findings were also mentioned in the

8EAP Mid-Term Review.111

The Commission issued in 2023 Guidelines on Member States’ adaptation strategies and plans to

support them in developing and revising their policy frameworks. However, due to their non-binding

nature, the guidelines have not managed to resolve the persisting gaps, as in many Member States risk

ownership, political commitment, coordination, capacity and sustainable financial resources are not

sufficient.

This driver, due to its nature, applies and contributes mainly to Problem 1.

107 (European Environment Agency, 2026c) 108 (European Environment Agency, 2025d) 109 (OECD, 2023) 110 (SWD(2023) 932 final) 111 (COM(2024) 123 final)

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2.3.1.3 Limited integration of climate resilience in sectoral decision-making processes

Across the EU and Member States, sectoral policies often consider climate resilience insufficiently

and inconsistently, if at all. The likely exposure and vulnerability to climate risks112 is insufficiently

reflected in sectoral policies, from energy to transport, to agriculture or financial services, to give just

a few examples. This leaves weak links and thus constrains effective and systemic climate risk

management, even in sectors with significant exposure.113 The overall preparedness of EU policy areas

is not sufficient as evidenced by EUCRA, indicating the exposures in policy areas, interlinkages

between the risks and policy areas, and the gaps in reducing such fragmentation of approaches (see

Annex 9).

Climate resilience dimension is to some degree present in a range of EU policies, such as the amended

Directive on Requirements for budgetary frameworks of the Member States114; the EU Taxonomy

Regulation115; the surveillance mechanisms for tracking climate risks used by the European Central

Bank, European Systemic Risk Board, and European Banking Authority; the PUS116; the Critical

Entities Resilience Directive; the Risk-Preparedness Regulation117 and the envisaged revision of the

EU energy security architecture118; certain tools of the Common Agricultural Policy; the European

Nature Restoration Law119; the Marine Strategy Framework Directive120; the Regulation on Serious

Cross-Border Threats to Health121; the EU Occupational Safety and Health (OSH) Framework

Directive122; the Union’s Environmental assessment instruments123; the Water Framework

Directive124; the European Ocean Pact125; the LIFE programme126; and strategies such as the EU Ports

Strategy127, EU Medical Countermeasures Strategy128, EU Forest Strategy129 and the European Water

Resilience Strategy 130. At the same time, the approaches to climate resilience differ, are not

coordinated and operationalised. For example, the Energy Performance of Buildings Directive does

address thermal comfort in buildings as part of considerations, but only as an element in the calculation

of cost-optimal levels of energy performance, to be transposed through national building regulations

and other actions; yet there are no clear objectives for this, and broader resilience of buildings is not

addressed.

112 Embedding climate resilience considerations into the design phase of EU legislation and policy decisions. See Annex

11 for a full definition. 113 (Cortés Arbués et al., 2025; EFCA, 2025; Gancheva et al., 2024; Leitner et al., 2024) 114 (EU) 2024/1265 115 (EU) 2020/852 116 (European Commission et al., 2025) 117 (EU) 2019/941 118 (European Commission, 2026g) 119 (EU) 2022 120 (EU) 2024/1991 121 (EU) 2022/2371 122 (89/391/EEC) 123 (European Commission, 2026b) 124 2000/60/EC 125 (European Commission, 2026h) 126 (European Commission, 2026d) 127 (European Commission, 2026f) 128 (European Commission, 2026e) 129 (European Commission, 2026c) 130 (European Commission, 2025a)

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The amended Council Directive 2011/85/EU on Requirements for Budgetary Frameworks of the

Member States does contain provisions requiring Member States to assess and report on how climate-

related macro-fiscal risks may affect the medium- and long-term sustainability of public finances, on

disaster- and climate-related contingent liabilities and on the fiscal costs incurred due to disasters and

climate-related shocks. Despite analytical progress, implementation approaches remain relatively

nascent and diverging across Member States.131 So far, there has been no systematic and structured

assessment of integration of climate resilience across EU policies; a tentative mapping of selected

policies and their potential coverage of the main dimensions of the initiative is included in Annex 10.

This mapping does not address the potential gaps in implementation as relevant, comprehensive and

sufficiently robust information is not available (reflecting the fragmentation and unclear distribution

of responsibilities), but from evidence presented in Annex 9 about increasing sectoral risks as well as

historical evidence on increasing losses, it can be inferred that lack of policy preparedness cannot be

fully assigned to regulatory failure and therefore insufficient implementation is also part of the problem

driver.

Whilst information on sector integration at Member State level is widely lacking, the EUCRA

finds that there are significant governance barriers which are hindering progress at Member State level,

and identifies a wide range of national policy competence areas that are exposed, such as spatial

planning, zoning or public finance management (See Annex 9).

Despite increased efforts since 2021 to integrate climate adaptation into sectoral policies, and to

strengthen links with disaster risk management and environmental assessment processes, the reported

information under the 2025 Governance Regulation indicates that adaptation across sectors is currently

unevenly integrated.

This driver, to different extent, contributes to all problems either directly (Problem 2) or indirectly

(Problem 1 and Problem 3).

2.3.1.4 Unclear climate risk ownership

Unclear risk ownership132and lack of democratic accountability contribute to slow and ineffective

progress. Research points to the ambiguity of risk ownership mandates between the EU and Member

States, which reduces policy coherence and effectiveness, and highlights policy areas in need of a

stronger EU role.133 Administrative capacity constraints exacerbate this situation e.g. many subnational

authorities lack the expertise, funding and tools for climate risk management134.

So far climate adaptation is primarily treated as the responsibility of environment and climate

ministries. This has severely hampered the understanding of risk ownership and consequently action

across sectors. The Climate Law’s provisions have been proven insufficient to improve adaptive

capacity across sectors, as mentioned in sub-section 2.3.1.2 and Annex 10. There are no minimum

content requirements, no common methodological standards, and no enforceable sectoral outcomes.

131 (European Commission, DG ECFIN, 2025). The Commission has been conducting scenario analysis reflecting climate

risks into its Debt Sustainability Analysis (European Commission. DG ECFIN (2026); European Commission. DG ECFIN

and Gagliardi, N. (2025); European Commission. DG ECFIN (2022)). 132 A governance concept that, in the EU adaptation context, defines the responsibility for managing climate risks. It is

strongly related to accountability. See Annex 10 for a full definition 133 (European Scientific Advisory Board on Climate Change, 2026) 134 (Intergovernmental Panel On Climate Change et al., 2023)

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The EEA Report135 confirms that risk ownershipand sectoral responsibilities are often unclear.

Responsibilities for managing climate-related risks are often spread across several ministries, agencies,

sectors and levels of governance, without clear accountability for who should act, by when and with

which resources. This is particularly important in sectors where adaptation decisions are made in

practice, such as buildings, land use, infrastructure, water management, health, agriculture and civil

protection. Where climate risks are not embedded in sectoral rules, standards and investment decisions,

adaptation remains difficult to operationalise.

Risk ownership, in the EU climate resilience building and climate adaptation context, refers to the

distribution of responsibilities between public authorities for policy decisions - including

implementation choices - that have the potential to reduce exposure or vulnerability to climate risks in

their primary domain and for other policies. (More details in Annex 11)

This driver contributes directly to Problems 1 and 2.

2.3.2 Methodological, evidence and informational barriers

2.3.2.1 Unclear vision, objectives, targets and indicators barriers

The visions, objectives, targets and indicators in EU and Member State climate adaptation and

preparedness strategies remain general and lack strong mandates needed for driving consistent

action across sectors and governance levels136 137(see Annex 10). Combined with divergences in the

understanding of the climatic futures that policies should prepare for, this prevents building

systemic climate resilience effectively. EU level reports to address this barrier do exist138, yet they use

indicators and provide information with limited relevance to climate resilience.139 Usually, Member

States and policy sectors choose independently what they deem most appropriate or available.

This driver contributes directly to Problems 1 and 2.

2.3.2.2 Methodology and terminology barriers

Climate resilience terminologies and methodologies – such as definitions of climate adaptation,

climate resilience, preparedness, risk, thresholds for drought events - are often understood and applied

differently. Together with diverging methodologies to conduct climate risk assessments they

undermine data comparability in the EUCRA and other climate risk assessments, complicating cross-

sectoral and cross-government coordination.

This driver contributes directly to Problem 1 and indirectly to Problems 2 and 3.

135 (European Environment Agency, 2026b) 136 (European Scientific Advisory Board on Climate Change, 2026), recommendation 3 (p14) 137 (OECD, 2025) 138 Notably reporting under the Governance Regulation and the adaptation chapters of the annual EU Climate Action

Progress Reports, also others such as the State of the Energy Union Report ESTAT SDG reports, 8 EAP monitoring, or

EU Semester reports. 139 (European Court of Auditors, 2024) The Court concluded that adaptation reporting “lacks common indicators for

measuring progress towards climate resilience by 2050” and therefore adds little value for strategic steering.

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2.3.2.3 Climate risk assessment (CRA) barriers

While the evidence base on climate risks is improving across Europe, it is not yet supported by

sufficiently harmonised approaches to national climate risk assessments. Methodologies, the use of

future scenarios and reference warming trajectories, sectoral coverage and timing of assessments vary

significantly across Member States. As a result, climate risks are increasingly identified, but not in a

sufficiently coherent and coordinated way. This leads to uneven levels of climate risk knowledge,

awareness and preparedness, and makes it difficult to assess how systematically climate risk evidence

informs adaptation policy development and implementation. This weak link reduces the ability to

prioritise action according to the most significant risks and can result in policies and action that are not

sufficiently targeting the most urgent risks or the most vulnerable sectors. Methodological diversity

across Europe further limits comparability and coherence, while insufficient cross-border cooperation

and data sharing leave shared and transboundary risks only partially understood and addressed140.

Across governance levels and policy sectors, large differences in CRA approaches and methods

undermine their comparability and effectiveness as a coherent foundation for policy and action,

hampering systemic climate resilience.141 At the EU level, whilst EUCRA filled critical evidence gaps

and offered a first, much-needed Europe-wide risk overview, its continuity remains unclear and relies

on political initiatives. At the national level, whilst 21 Member States had climate risk assessments by

2025142, there are still significant shortcomings and differences e.g. in risk structure, quantification,

scenario use, coverage of systemic and cascading risks. The main gaps concern the availability and

interoperability of data, the technical expertise needed for integrated and systemic risk assessment, and

the financial and institutional capacity required to translate CRA findings into action. These constraints

weaken the uptake of risk knowledge in adaptation planning and implementation, and risk widening

preparedness gaps between countries.

This driver contributes directly to Problem 1.

2.3.2.4 Climate adaptation planning and design barriers

Climate adaptation planning across the EU remains inconsistent, with wide variations in

methodologies, and ambition. At the national level, the 2023 Guidelines on Member States’ adaptation

strategies and plans143 could so far not prevent large variations in their methodologies. Many countries

continue to struggle with coordination across sectors and governance levels, particularly in

decentralised and federal systems. Fragmented mandates, unclear roles and limited administrative

capacity reduce the coherence, effectiveness and efficiency of adaptation planning, even where

strategies and plans are in place. This variety of approaches prevents the effective management of

the many shared, transnational and systemic climate risks.144

This driver contributes directly to Problem 1 and indirectly to Problems 2 and 3.

140 (European Environment Agency, 2026c) 141 (European Commission. DG ECFIN, 2022, 2025; European Environment Agency, 2024; Luo et al., 2023; Newman et

al., 2023; Schwarzwald et al., 2022; Stern, 2007) 142 (European Environment Agency, 2025e) 143 (European Commission, 2023a) 144 (European Commission, 2024b)

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2.3.2.5 Progress monitoring and assessment barriers

Current frameworks for monitoring, reporting, evaluation, and learning (MREL) allow only limited

tracking of the effectiveness of climate resilience and adaptation policies, restricting insights into

progress (as mentioned in section 2.3.2.5 and Annex 10). Developing suitable metrics for adaptation

is often challenging due to the diversity and complexity of climate risks and adaptation responses.

Compared to monitoring and reporting, policy evaluations as less common among Member States. At

the national level, many countries lack robust evaluation systems with shared guidelines or indicators,

making it hard to compare progress across Member States, assess the effectiveness of measures, justify

investments, or refine strategies. An additional barrier here is that sometimes the effects of a particular

adaptation response are only visible after a delay, which can make it hard to evaluate certain

activities145. MREL limitations also prevent financial institutions and insurers from pricing climate

risks.146

This driver contributes to Problem 1.

2.3.3 Information and know-how barriers:

Access to reliable, actionable data and skills remain insufficient to adequately support climate

risk management decisions. Limited awareness and use of EU adaptation tools and knowledge

platforms at local level was identified as a shortcoming by the ECA147. EU-level tools providing

climate resilience data remain underused, for various reasons: they are too technical (e.g. the C3S

Atlas), provide too coarse information (e.g. the European Climate Data Explorer), key users are not

aware of them (e.g. Climate-ADAPT)148, and have difficulties in understanding their methodologies.

Data formats of current tools are often inconsistent, and quality of external information reported is not

always ensured. Current tools also tend to overlook systemic risks. National tools do exist, yet with

different scopes and approaches, limiting their comparability and use for cross-sectoral, cross-border

and multi-governance level purposes149.

Also, economic impact data are not complete enough for a comprehensive assessment macro-fiscal

impacts and risks150 and incomplete vulnerability data and uncertain risk projections create significant

uncertainty for large European corporations.151

At the Member State level, implementation is constrained by uncertain financing and limited capacity

(staffing). Few Member States have dedicated adaptation financing mechanisms that track and ring-

fence resilience expenditure separately from broader disaster response and recovery spending. Limited

institutional and technical capacity, especially at regional and local levels, restricts the translation of

national priorities into targeted measures on the ground. Low. Moreover, funding going into skills for

innovation is not always well coordinated towards innovation needs.152

145 (European Environment Agency, 2026c) 146 (European Central Bank et al., 2023; European Scientific Advisory Board on Climate Change, 2026; Leitner et al., 2024;

OECD et al., 2022; United Nations Environment Programme et al., 2024) 147 (European Court of Auditors, 2024) 148 (Copernicus Climate Change Service, 2024; European Court of Auditors, 2024; European Environment Agency, n.d.) 149 (European Environment Agency, 2024) 150 (European Commission. DG ECFIN, 2025) 151 (Cortés Arbués et al., 2025) 152 (European Commission, 2024g; European Commission, 2024h)

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This driver contributes to, to different extents, to all the identified Problems.

2.3.4 Market failures

There are three interconnected market failures that distort investment decisions when it comes

to factoring in future climate conditions. Firstly, the true costs of inaction – damage to infrastructure,

public health burdens, productivity losses – are not internalised, skewing incentives toward short-term

considerations. Many of these costs are borne by actors other than those making investment decisions.

For example, governments frequently absorb a substantial share of the costs of disaster response,

reconstruction and emergency support, while healthcare systems bear the costs associated with heat-

related illnesses, disease outbreaks and deteriorating air quality. Supply chain disruptions and

productivity losses often affect entire sectors and regions rather than individual firms (e.g. Rhine low

water in 2018 and 2022 that affected several sectors153). As these wider societal costs are not fully

reflected in market prices, firms and investors may face limited incentives to invest in adaptation

measures whose benefits accrue primarily to society as a whole.

Secondly, the benefits of adaptation materialise over the long term and are inadequately monetised,

which weakens the case for investment and reinforces inaction. Unlike investments that generate new

revenues or increase productivity, adaptation measures typically create value by reducing future losses

and preserving existing economic activity. Their benefits are therefore realised through damages

avoided rather than income generated. This creates significant measurement challenges, as avoided

losses are inherently counterfactual and depend on uncertain future climate conditions (see Annex 8

and examples in chapter 6). Conventional investment appraisal frameworks frequently struggle to

capture these benefits, particularly where project evaluation periods are short or discount rates place

less weight on long-term outcomes. As a result, many adaptation measures that would deliver

substantial economic benefits over their lifetime appear less attractive than investments with more

immediate and easily quantifiable returns.

Thirdly, climate risks are not reliably priced in across financial markets, infrastructure planning

and public procurement. The asset pricing often relies on historic data154 that do not reflect the new

risk patterns that will emerge because of climate change. The nature of the risk is long-term and

depends on complex interactions between climate variables and socioeconomic developments that are

difficult to model. According to the ESRB155, the incomplete incorporation of climate-related risks in

market prices can cause assets to be overestimated or liabilities to be underestimated, affecting both

financial institutions (mainly through holdings of financial assets) and non-financial corporations

(particularly through tangible assets measured at fair value, such as investment property. ECB

supervisory mandate also underlines that modelling and quantification of climate risks is subject to

significant underestimations by banks.156 Thus, markets may not price future physical risk

correctly, potentially leading to capital misallocation and economic inefficiency.

153 In a month with 30 days of low water, industrial production in Germany declines by about 1 percent, ceteris paribus,

according to study by Ademmer, et al. (Ademmer et al., 2020). 154 ESRB advice to EBA shows historical data use is standard (ergo not considering future climate): conventional risk

management methods used by financial institutions and supervisors may not be suitable for properly capturing the full

range of climate-related financial risks, methods are based on historical data that do not reflect the new risk patterns that

will emerge as a result of climate change 155 (European Systemic Risk Board., 2024) 156 (European Central Bank, 2025)

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Together these failures produce wrong price signals that perpetuate and deepen the preparedness

gap. These distortions are further compounded by information asymmetries, as investors, lenders and

households often lack access to consistent, forward-looking information on physical climate risks and

the effectiveness of adaptation measures and do not factor them in their decisions, as confirmed also

by the ECB 2022 climate risk stress test.157

An important example of this effect is the 2021 floods in Germany, which caused more than EUR 33

billion in damages.158 After the disaster the average property prices in flood-prone areas did not adjust

to account for flood risk. Meaningful price declines occurred only in areas located close to the flooding

or in regions shown to have higher levels of climate-change awareness.159 This shows that flood-risk

valuation does not adjust uniformly across the market and can lead to “suboptimal capital allocation”,

potential overinvestment in flood-prone areas and demonstrates how climate risks remain inadequately

priced into market decisions despite existing flood-risk regulations. This example shows that market

prices can continue to underestimate physical climate risks and lead to increase of future economic

losses as climate impacts intensify.

Short-term perspectives and shareholder pressures, focused on annual returns, hinder long-term

resilience investments, even if they promise substantial long-term gains, leading to underfunding and

overreliance on outdated climate data rather than forward-looking scenarios160. Estimating potential

losses from indirect impacts (supply chain disruption, labour productivity etc.) is challenging, and

physical climate risks remain underpriced: though natural disasters cause financial losses, equity

valuations and markets show little reaction to major climate shocks.161 Consequently, private resilience

investment stays low - particularly in manufacturing, a key GDP driver in Europe - risking locked

vulnerabilities and higher future costs162. Despite vast market potential for climate solutions, resilience

also remains an innovation blind spot.163 The fact that governments bear costs of disaster

management, not only results in a sense of complacency and disincentivises risk aversion by citizens

and industry but also strains public budgets and diverts funds from education and R&D, undermining

competitiveness.

Finally, there is a growing transfer of risks to an insurance industry, which is either unable or

unwilling to accept them. This is leading to a widening protection gap as insurers increase the

complexity of underwriting in a bid to reduce their payouts and protect their operating model. Beyond

this, the structural erosion of insurability stems from the increased frequency and severity of losses.

As risks are non-linear and geographically correlated, this limits the extent to which they can be priced

using solely historical data. Therefore, conventional mechanisms are constrained which limits the

ability for insurers to offer coverage that is broad and affordable, even in places where demand is

strong. Moreover, households and investors are encouraged to rely on insurance as a de-risking

mechanism, while the parallel implementation of risk reduction measures would be beneficial to

improve long-term insurability.164 (see also Annex 8)

157 (European Central Bank., 2022) 158 (Ulrich et al., 2026; Zenker et al., 2024) 159 (Gruhl et al., 2025) 160 (EFCA, 2025; European Environment Agency, 2024) 161 (European Commission. DG ECFIN, 2025) 162 (Cortés Arbués et al., 2025) 163 (McKinsey, 2025a; Tailwind, 2024) 164 (Climate Resilience Dialogue, 2024; Crugnola-Humbert, 2025)

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This driver contributes directly to Problem 2 and indirectly to Problems 1 and 3.

2.3.5 Behavioural barriers

Behavioural responses to climate risks are strongly influenced by framing, reference points, personal

experience, and emotional salience rather than objective data. Behavioural barriers - such as short-

term thinking, cognitive tunnelling165, and risk misperception – increase the gap between high

climate concern and low preparedness. Climate resilience is often seen as a long-term challenge

whose benefits materialise beyond electoral cycles, competing with more immediate priorities like

economic growth or energy security166. Public-sector ambiguity on climate risk management also

discourages private investments in long-term, systemic solutions167. Without compelling, positive

narratives on climate resilience, risk awareness, risk perception and risk ownership remain weak,

which combined with the market failures described above, results in stalling action by individuals,

companies and governments.

This driver contributes to all the identified Problems.

2.4 How likely is the problem to persist?

Climatic hazards will continue to increase, with existing policies insufficient to keep pace. The

persistence of the problem and of its drivers have been set out in this and the previous chapter,

evidenced by the EUCRA and other major studies in the field, and summarised in early 2026 by the

European Scientific Advisory Board on Climate Change (ESABCC)168. The persistence of the problem

is also echoed in the EU strategic foresight report from 2025, which presents key long-term megatrends

and EU-specific challenges, identifying climate resilience as a key area for action169.

The preparedness of European economy and society to climate risks is one element of overall societal

resilience, and the two are interrelated:

• Forceful, comprehensive solutions in sectoral policy areas (e.g. structural and systemic

infrastructure security approaches, water resilience policies) may reduce climate vulnerabilities

and exposures, even without additional horizontal climate resilience and adaptation action. Yet,

the identified problem drivers strongly suggest that this effect will be very limited at best.

• As such, horizontal climate resilience and adaptation policies and actions will not be enough to

deliver overall resilience of the society, but they are an essential part of it, as recognised also in the

Preparedness Union Strategy and its relevant actions, such as the Comprehensive Risk and Threat

Assessment and the nonbinding Minimum Preparedness Requirements.

Therefore, the described problems are highly likely to persist and amplify without additional

interventions to tackle the identified barriers, as a contribution to overall societal resilience. Chapter

5.1 on the policy baseline provides more details on projected developments.

165 (Mani et al., 2013; Mullainathan et al., 2013; Shah et al., 2015) 166 (OECD, 2025; United Nations Environment Programme, 2021) 167 (European Commission. DG CLIMA, 2025d) 168 (European Scientific Advisory Board on Climate Change, 2026) 169 (European Commission. Secretariat General., 2025)

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3 WHY SHOULD THE EU ACT?

3.1 Legal basis

This initiative is based on Article192(1) of the Treaty on the Functioning of the European Union

(TFEU), on Union policy on the environment170. There are also several other Treaty provisions of

relevance to the initiative, such as Articles 114 (internal market), 122 (emergency measures), 168

(public health), 194 (energy policy) and 196 (civil protection).

3.2 Subsidiarity: Necessity of EU action

Climate hazards increasingly affect the entire EU territory and put core Treaty objectives and policy

areas at risk171, thus demanding strong EU-level action.

Many climate risks are shared between MSs because of their cross-border, transboundary dimension.

River basins, seas, energy grids, transport networks, supply chains, ecosystems, infectious disease

pathways, financial systems, markets and societies span across national borders. Impacts can cascade

and compound at broader economic and societal level degrading Union-wide cohesion, financial

stability and investment outlook, posing a wider systemic threat with considerable potential to impact

on the free movement of goods, services, capital and persons between countries.

MSs addressing these shared risks in varying ways will not deliver the same result as a joint approach.

To be efficient and effective, climate resilience policies require more uniform application, and

coordinated action across different sectors and governance levels. Weak links between risks and

policies can be prevented to avoid compromising the prosperity and safety of all EU citizens and

industry.

EU-level action on climate resilience and adaptation is also needed because, at the international level,

the EU has committed to achieving the Global Goal on Adaptation under Article 7 of the Paris

Agreement172, and is party to other international agreements with important climate resilience

aspects173. This need is further underpinned by the Treaty principle of sincere cooperation, external

representation and the coordination of Union and Member State action in international agreements and

multilateral fora, as well as the Union’s objective of promoting measures at international level

combating climate change under Article 191 TFEU.

In sum, climate impacts can undermine the effective delivery of EU policies including the functioning

of the single market, as well as the Union’s ability to uphold its fundamental rights and pursue its

international obligations and promote more ambitious approaches internationally. Actions at the

national level would not be sufficient in addressing climate risks. Policy intervention at the EU level

170 (Consolidated Version of the Treaty on the Functioning of the European Union, 2012) 171 These include security, social justice and protection, economic growth, fiscal and financial sustainability, territorial

cohesion, public health, food security, a functioning internal market, environmental protection, and marine biological

resources under the common fisheries policy. 172 Article 7 of the 2015 Paris Agreement established the Global Goal on Adaptation more details. 173 E.g. Espoo Convention; Convention on the Protection and Use of Transboundary Watercourses and International Lakes;

Kunming-Montreal Global Biodiversity Framework, 2022; Sendai Framework for Disaster Risk Reduction 2015 - 2030,

2015; Transforming our world: the 2030 Agenda for Sustainable Development, 2015; Convention to Combat

Desertification, 2017)

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– in concert with national, regional and local action - is necessary to effectively and efficiently achieve

the needed levels of systemic, EU-wide climate resilience and preparedness levels.

3.3 Subsidiarity: Added value of EU action

This initiative is expected to generate added value over and above what the Member States can achieve

nationally for the following reasons:

• The magnitude and complexity of the challenge, and the fact that climate change affects many

policy areas of shared competence, requires an all-of-government approach that includes

intervention at the EU policy level.

• Complementing different national policies and rules, EU-level action is needed for promoting a

more harmonised and coherent understanding and approach to climate resilience at national and

subnational level and across policy areas, thereby effectively reducing transnational, cross-border

and systemic risks.

• In addition to contributing to greater effectiveness, EU-level intervention for climate resilience has

significant potential for achieving policy objectives in a more cost-efficient manner. For instance,

a single EU-wide early warning and surveillance system for wildfires or climate-sensitive

infectious diseases is cheaper and will deliver better results on these cross-border impacts

compared to the development and operation of separate systems by each Member State.

• Similarly, improving the functioning of the internal market for climate resilience products and

services (e.g. heat-protection gear for workers, less water intensive and more climate resilient

crops, smart building cooling solutions) holds potential for economies of scale, greater

competitiveness at the global scale, and better leverage over global norms and regulatory standards.

• Strengthening the role of climate resilience in EU budgetary and economic governance frameworks

not only provides a common direction to public authorities, but also – by extension - to the private

sector and citizens.

• EU-led policies and support measures for climate resilience have a bigger chance of leading to true

transformation. These will not only make the EU and the Member States more prepared to face

current and future climate risks, but also strengthen core values of the Union, such as solidarity,

cohesion and reduction of inequalities.

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4 OBJECTIVES: WHAT IS TO BE ACHIEVED?

4.1 General objective

To address the problems identified in chapter 2, the general objective (GO) is to make EU and its

Member States more resilient to current and future climate risks. This objective contributes to

implementing

• the Political Guidelines 2024-2029 of the Commission, and the priorities of the 2024-2029 strategic

agenda174;

• the objectives of protecting the environment and human health, and dealing with the worldwide

problem of climate change, with a view to promoting sustainable development (Article 191 TFEU);

• the European Climate Law and Article 7 of the Paris Agreement, which require the Union

institutions and its MS to enhance adaptive capacity, strengthen resilience, and reduce vulnerability

to climate change.

• of strengthening the EU’s long-term competitiveness and strategic autonomy, as highlighted in the

Draghi175 and Letta176 reports, by enhancing resilience to climate risks, safeguarding productivity,

supporting innovation, and ensuring a stable and predictable environment for sustainable

investment and economic growth.

174 (European Union, 2024) 175 (European Commission. European Political Strategy Centre., 2025) 176 (Enrico Letta, 2024)

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4.2 Specific objectives

The specific objectives (SO) of this initiative address the key problems and drivers identified in

Chapter 2.2. This impact assessment will evaluate the capacity of the different policy options to deliver

them.

Figure 2: General objective, problems, and specific objectives

SO1: Climate risk ownership is clarified in EU and Member States across all governance levels

and sectors

This SO relates to problem 1 fragmentation of climate resilience in the EU and Member States. As

outlined in chapter 2, the multilevel governance structures of climate resilience – including horizontal

and sectoral policies – can lead to unclear allocation of responsibility for identifying and addressing

climate risks. By integrating climate risk ownership systematically into EU and Member States

governance levels and sectors, responsibilities for identifying, assessing and addressing climate risks

are clearly allocated in public authorities. The objective aims at strengthening coherence and

accountability in climate resilience planning and implementation both within horizontal climate

resilience policy and sectoral policies, while maintaining flexibility for national and subnational

governance arrangements and sectoral competences. Implementation and progress will be monitored

through relevant planning and reporting processes. Clarifying climate risk ownership will help reduce

gaps, duplication, overlaps and inconsistencies.

SO2: Policy and implementation decisions by climate risk owners consider current and future

climate risks and support climate resilience

This SO addresses the misalignment between existing policy-making processes and the growing scale

and complexity of climate risks and impacts. Climate risk assessments should be based on a common

GO: Make EU and its MS more resilient to current and future

climate risks

P1: Fragmented climate resilience in the EU and MS

SO1: Climate risk ownership is clarified at EU & MS across all governance levels & sectors

SO2: Policy & implementation decisions of climate risk

owners consider current & future climate risks and

support climate resilience

P2: Unprepared private sector

SO3: Private sectors are aware & enabled to better identify and manage their current &

future climate risks

P3: Unpreprared population

SO4: EU population is aware & enabled to better identify and

manage its current & future climate risks

34

vision of future climatic conditions stemming from the global warming trajectory, allowing to anchor

the proposed adaptation options and to ground subsequent decisions on risk ownership and climate

resilience by design on the outcomes of those assessments. Once risk ownership is clearly defined,

responsible authorities, supported by the appropriate instruments, will be better positioned to assess

and address both current and future climate risks. This will enable more informed and forward-looking

policy decisions, integrating climate resilience considerations from the outset. As a result, policy

implementation will be more coherent, coordinated and efficient across sectors, strengthening the EU’s

overall resilience and preparedness to climate change.

SO3: Private sector actors are aware and enabled to better identify and manage their current

and future climate risks

Climate risks and impacts affect both public and private actors alike. Strengthening the climate

resilience of the EU economy therefore requires an active engagement from the private sector. When

public authorities provide clear signals and adopt forward-looking policies and decisions, awareness

among private sector actors of their exposure to climate risks increases. Supported by the appropriate

instruments, this will incentivise the development of a climate resilient economy, strengthen leadership

in developing markets, provide signals to stimulate investment, create competitive advantages for the

EU globally, and contribute to job creation and growth.

SO4: The EU population is aware and enabled to better identify and manage its current and

future climate risks.

Population preparedness is also essential to improving societal climate resilience. EU populations need

to have an improved understanding of the risks they face and their capacity to respond. By ensuring

clear and accessible information on risks and measures to combat these, communities across the EU

can better anticipate and adapt to both current and future climate risks, while also improving public

acceptance for building climate resilience. More transparent design and implementation processes also

contribute to support and protection specifically for vulnerable groups, by promoting a fair, inclusive

and participatory approach to climate resilience and adaptation.

5 WHAT ARE THE AVAILABLE POLICY OPTIONS?

5.1 What is the baseline from which options are assessed?

The baseline option represents a ‘no policy change’ projection that considers the effects of current

policy measures and their interactions. It serves as a counterfactual, against which the incremental

impacts of the policy options and measures can be assessed. It also allows identifying remaining policy

gaps and avoidable risks regarding climate preparedness under a business-as-usual policy scenario.

At the EU level, considering the current horizontal climate resilience policy framework, the

baseline comprises of the continuation of the EU Adaptation Strategy, European Climate Law and the

Governance Regulation (see Annex 10). Under the baseline, the obligations defined in these policies

would continue to guide EU and Member State action on preparedness and climate resilience. The

European Climate Law and Governance Regulation would remain the main binding elements of the

horizontal policy framework, requiring Union and Member State planning, reporting and progress

assessment. The EU Adaptation Strategy, Commission Communication on managing climate risks and

35

subsequent editions of EUCRA would continue to support policy development and implementation on

a non-binding basis.

The baseline would allow for some continued progress, through planned policy reviews, informed by

emerging climate risk evidence, and this could support gradual and slow improvements in

policymaking and coordination.

However, in the absence of additional policy change, progress would continue to depend largely on

the current (unclear) distribution of responsibilities, existing EU coordination and support

mechanisms, the (uneven) level of implementation by Member States and the voluntary uptake of non-

binding instruments and existing reporting requirements. It would also do little to clarify policy risk

ownership and improve fragmented policy approaches, implementation, financing, management of

shared and cross-border climate risks, progress monitoring and the evidence on the effectiveness of

adaptation measures.

The baseline is thus unlikely to fully address the identified main problem of fragmented and

insufficient preparedness for current and future climate risks. Instead, it can be expected to continue

current trends, with persistent differences across Member States, sectors and governance levels in

climate preparedness and resilience.

However, because of the voluntary nature, diversity of methods and reference scenarios, and

fragmentation of approaches in planning and implementation would remain substantial. This would

for example then entail the following consequences:

• due to lack of coordinated cross-sectoral effort the ambiguity of policy risk ownership between

the EU and Member States is not solved;

• an operational, integrated EU-wide system for setting horizontal climate resilience objectives

and targets, as well as robust progress monitoring and assessment with common indicators and

baselines is not established.

• transformative push triggering increasing ambition and coherence of action across sectoral

policies is not achieved.

EU sectoral policies and measures are underprepared as demonstrated in section 2.2.1 and Annex 10.

While the sectoral policies consider the climate risks and resilience in varying degrees, they do have

different approaches (see section 2.3.1.3). As a result, the risks in policy areas are projected to increase

without further action.

At face value, the inclusion of some climate resilience dimension in a wide range of policies presents

an impressive regulatory and policy lineup. At the same time, Annex 10 demonstrates that these are

not currently ready to address the key elements of the initiative designed to address the problem

drivers. Whilst the current policies will likely have some effect, the integration of climate resilience

has so far progressed in a fragmented and incremental way, raising concerns about overall policy

coherence, reflecting the lack of an overarching and coherent framework to guide action. Without a

reference scenario for what climate reality to expect, these tools will also remain flawed and

incomplete. In the baseline option, the policies at EU level are likely to continue developing in similar

fashion, with expected improvements for example through the upcoming Multiannual Financial

Framework and through European Semester:

• The July 2025 Commission proposal for the next Multiannual Financial Framework mentioned

the need for EU funding to promote preparedness and resilience (also to climate risks) in the recitals

36

and objectives of the acts that will govern the different funds, including the National and Regional

Partnership Plans177, the European Competitiveness Fund178, Horizon Europe179 and the Union

Civil Protection Mechanism180. The proposed horizontal Performance Regulation181 lists

intervention fields for dedicated climate resilience measures, and one of the three co-efficients

tracking spending towards the overall 35% green target will cover climate adaptation. Specific

decisions regarding criteria, including the simplified approach to the Do No Significant Harm and

possibly climate resilience proofing are currently being discussed.

• The 2026 European Semester Package aims to boost competitiveness, secure strategic

autonomy, increase resilience, and strengthen preparedness while maintaining fiscal sustainability.

The Commission has concluded that enhancing climate resilience is among the key priorities to

meet these objectives in 11 Member States, adding to other 9 Member States from previous

years182. The EU Semester reports pinpoint specific climate resilience issues to be addressed in

individual Member States, e.g. climate resilience governance, inadequate insurance, need for

investments, climate-proofing of infrastructure, use of nature-based solutions, etc. Furthermore,

these country-specific recommendations shall inform priorities of the future national and regional

reforms and investments of individual Member States. The scope and coverage of climate

resilience aspects in the Semester process depends on the relative urgency between policy priorities

in the coming years.

However, although some existing instruments might continue strengthening climate resilience in their

respective areas (for example through revisions of sectoral legislation), these developments are likely

to be reactive to events and remain fragmented and sector specific. This approach will not ensure the

required levels of systemic and coherent resilience and preparedness action (including anticipation,

precaution, risk ownership, accountability, planning, resourcing, implementation and progress

monitoring) across all policy areas. As there is no EU-wide framework to track and assess progress,

availability of data remains scarce, making it difficult to assess sectoral and climate policies efficiency.

By 2050, if global warming exceeds 1.5°C (current projection indicate 2°C) and no additional policy

action is taken, food prices in Europe could increase by 20%; and by 2041–2060, expected annual

economic damages from pluvial and fluvial flooding are projected to reach approximately EUR 13–

29 billion across Europe, representing an increase of 110–150% due to climate change alone, while

the number of people affected annually could increase by around 150%.183 In the longer-term, the

proportion of EU citizens aged over 65 is projected to increase from around 19% today to

approximately 30% by 2100 – which means extreme heat-related mortality in the EU may increase

approximately tenfold under a 1.5°C global warming level, and by more than thirtyfold under a 3°C

warming scenario.184

177 (European Commission, 2025d) 178 (European Commission, 2025g) 179 (European Commission, 2025f) 180 (European Commission, 2025h) 181 (European Commission, 2025e) 182 Climate resilience is a subject of country-specific recommendations (CSRs) for 7 Member States, and of recitals for

another 4 Member States in 2026. Further 11 Member States have received CSRs on climate resilience in previous

European Semester reports. 183 (European Environment Agency, 2024) 184 (European Environment Agency, 2024)

37

A similar picture emerges when forecasting trends at the national level, under a ’no policy change’

scenario. Section 2.2.1 demonstrates that while there is some progress in policy and action for climate

resilience in many Member States, policy approaches are fragmented and many sector policies in

national competence are exposed, such as spatial planning, heat-health planning or public financial

management (see section 2, Annex 9). There is limited direct and comparable information on

implemented sector actions in Member States and their effectiveness, which hinders a full

understanding.

Each Member State has adopted a national adaptation policy. Typically, environment or climate

ministries are responsible for NASs and NAPs. Some Member States have also subnational climate

adaptation plans, e.g. Belgium, Finland, Germany, Greece, Portugal and Sweden, but there is no

systematic approach across the EU. Specific sectoral climate adaptation plans are not very common,

with just four Member States reporting these (Finland, Ireland, Spain and Sweden).185 Most countries

highlight their adaptation policies as central instruments for mainstreaming. While Member States

make effort to integrate adaptation in overall sectoral policies, based on the information available, it

can be concluded that progress is uneven186. As of 2026, 14 Member States have incorporated climate

adaptation into national climate laws.187 There is limited direct and comparable information on

implemented actions and their effectiveness, which hinders a full understanding of progress and

challenges. Adaptation policies are diverse, fragmented and hard to compare and cross-evaluate with

regard to objectives; specific climate risks to be addressed; governance structures; levels of horizontal

and vertical integration; data sources, methods and models used, instrument mix; and outcome/impact

progress monitoring188.

Under a ‘no policy change’ baseline, it can be expected that Member State policy development and

implementation approaches continue being fragmented and data on implementation and progress on

climate resilience will remain limited. Disparities between Member States are expected to persist or

widen, as some with stronger institutional capacity, data availability and financial resources may

progressively adopt more anticipatory and integrated resilience approaches, potentially creating

examples to follow, but others may remain primarily focused on short-term disaster response and

recovery following extreme events, with limited capacity to implement long-term resilience planning.

The projected losses due to these incomplete resilience policies and preparedness vary across countries

and models. SwissRE estimates189 that in a severe scenario of a 3.2°C temperature increase, Europe

would suffer the loss of about 11% of GDP before 2050. Economies such as Finland or Switzerland

are less exposed (6%) than, for example, France or Greece (13%). Another estimate says that extreme

weather due to climate change may cost Italy more than 5% of GDP in 2050190.

In brief: the ‘no policy change’ baseline is not commensurate with the scale, pace and complexity of

increasing climate risks. Put simply: doing nothing will cost us a lot. Whilst government policies and

actions will evolve, bigger changes will likely happen only in response to acute crises and limited to

the sectors or geographical areas affected. The continuation of today’s climate resilience building and

185 (Climate ADAPT, 2016) 186 (European Union, 2025) 187 (European Environment Agency, 2025c) 188 (Bukowska et al., 2023; European Environment Agency, 2025g; Leitner et al., 2024; Zobeidi et al., 2025) 189 (Swiss Re Institute, 2021) 190 (Reuters, 2025)

38

adaptation efforts across the EU and its Member States can be expected to remain insufficient, largely

incremental, fragmented, often coming too late and causing unnecessary costs.

5.2 Description of the policy options

Addressing fragmentation of preparedness for climate change impacts

Chapter 2 presented the overall problem of fragmented and insufficient preparedness of the European

economy and society for climate impacts, which can be further broken down into P1- Fragmented

climate resilience in EU and Member States, P2 - Unprepared private sector, and P3 - Unprepared

populations. All of the problems are caused by very similar drivers, albeit to a different extent. It needs

to be noted that as there are interlinkages between the problems, there will be also interlinkages

between the proposed approaches.

The overall problem can be addressed through harmonisation and increase of the overall level of

preparedness by ensuring that the minimum elements for achieving systemic climate resilience are

delivered at all levels of government and across all policy sectors. To prepare for climate impacts it is

important to understand first that they are the result of materialisation of climate risks. Since climate

risk is a product of hazard, exposure and vulnerability, and the climate hazards are expected to keep

increasing (see Annex 12), a forward-looking, anticipatory preparedness will mean lowering exposures

and vulnerabilities. Also, to improve the level of preparedness, such actions need to happen at a faster

pace than the projected hazard increases. To increase and harmonise preparedness, it is important that

actors have a common knowledge about the future climatic conditions, the evolution of hazards, as

well as an appropriate level of climate risk awareness and perception.

While talking about the preparedness of the European economy and society and it is important to

distinguish here between policy preparedness and physical preparedness/resilience. Since EUCRA

analysed policy characteristics (policy horizon, policy readiness, risk ownership) andtranslated

theminto urgency classes, it provided the best available comprehensive proxy for policy

preparedness. The economic losses and fatalities data reflect physical preparedness. Policy and

physical preparedness are closely interlinked, with policy preparedness being often a condition and a

driver for physical preparedness. If addressed together, they can improve and harmonise the overall

preparedness for climate impacts.

The initiative does not seek to resolve the physical preparedness problem by imposing direct climate

preparedness requirements such as e.g. mandatory flood defences for 100-year flood event. Instead, it

aims to improve physical preparedness through enhanced policy preparedness at EU and

Member State levels at all stages of the adaptation policy cycle.

The adaptation policy cycle describes the main stages through which adaptation policy is developed,

implemented and revised. In line with the UAE Framework for Global Climate Resilience, the cycle

starts with assessing climate risks and vulnerabilities. This evidence informs the formulation of

adaptation objectives and targets, and the identification and selection of priority adaptation measures,

usually consolidated in an adaptation plan. The next stage is the implementation of measures,

followed by monitoring, evaluation and learning to assess progress, results and remaining gaps. The

cycle is iterative. New climate risk knowledge, lessons from implementation and findings from

tracking progress inform the next generation of plans and measures. Each step is explained in detail

under for e.g. the Regional Adaptation Support Tool, developed for the needs of the Mission on

39

Adaptation191.The harmonised adaptation policy cycle between the EU and Member States would be

built along the elements in Figure 3.

Figure 3: Harmonised adaptation policy cycle

The harmonisation of the adaptation policy cycle and providing digital tools to support its

implementation will allow to address most of the drivers contributing to the identified problems. The

general objective and desired ultimate effect of this initiative require both incremental and

transformational approaches that build adaptive capacity and address root causes of vulnerability192.

This requires systematic, consistent and effective policy decisions and measures across all levels of

government and in all policy sectors, as outlined under ‘outputs’ and ‘outcomes’ in Figure 4.

To create the conditions for delivering these outputs and outcomes, this report has considered three

policy options - each characterised by a distinctive set of main policy measures and reflecting different

intensities of intervention and a different balance between mandatory and voluntary measures.

The initiative aims to address the main problems by dealing with their main drivers. Most identified

drivers are underlying more than one problem, so dealing with them will allow to improve compared

to the baseline. The drivers, and through them, the problems, can be addressed by a set of measures

designed to: ensure a common view of the climatic future, which will be directly applicable to all

policies; improve and harmonise the adaptation policy cycle in the EU and Member States, and enable

and empower public and private actors.

To meet the objectives of the initiative (Chapter 4), a set of core elements (also reflecting the

recommendations by ESABCC193) to improve policy preparedness for future climate risk has been

identified:

191 (Climate ADAPT, 2026 192 (European Scientific Advisory Board on Climate Change, 2026) 193 (European Scientific Advisory Board on Climate Change, 2026)

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1. A common vision and understanding of strengthened resilience based on clear climate

resilience objectives194 and a “duty to consider”195 requirement for risk owners to reflect how

these objectives are achieved in their decisions in their respective policy areas, making their

policies climate resilient by design. 196

2. A scientifically solid and reliable reference global warming trajectory (Annex 12) - from now

on referred to as “reference warming trajectory” - to provide a connecting element for

decisions at all governance levels.197 A reference warming trajectory for near, medium and long-

term time horizons will be set, based on authoritative available scientific evidence and the

precautionary principle. The trajectory may be updated when material, new information becomes

available.

3. More aligned national and EU assessments of climate risk to provide evidence for climate risk

management options and improve the comparability of the risks under various climate

scenarios that may have transboundary or Union implications.

4. Based on the information provided by the climate risk assessment the policy risk owners will be

identified. Risk ownership, in the EU adaptation context, refers to the distribution of

responsibilities between public authorities for policy decisions (including implementation choices)

that have the potential to reduce exposure and/or vulnerability to climate risks in their primary

domain and for other policies. The risk ownership is policy, system and asset based i.e. a ministry

in charge of a specific policy domain will need to consider the climate exposure of the policy,

system or material assets in their policy remit. Such policy risk ownership is strongly related to

accountability. It does not refer to or prejudge the ownership of financial risks, which are

distributed across public and private stakeholders.

5. The policy risk owners will follow the climate resilience by design principle, which is part of the

concept of Preparedness by design and means embedding climate resilience considerations into the

design phase of EU legislation and policy decisions as well as investment and financing decisions.

Climate resilience by design means reducing exposure and/or vulnerability under plausible future

climates from the outset to the extent possible, thus enhancing readiness and action across sectors

to ensure that increasing hazard events do not become unexpected crises. The approach is

anticipatory and complements the disaster risk management measures that deal with the residual

risks. (More details in Annex 11)

6. The decisions on tolerable level of risk will be made by the competent authority to balance

competing policy objectives within practical constraints. The definition of risk will vary across

policy areas and risk owners but should follow three steps: identify and characterise the hazard;

assess the likelihood of its occurrence; and characterise the risk – quantitatively and if not possible,

qualitatively198; identify the available measures to reduce the risk, and consider and document the

decisions made regarding implementation of such measures, in light of national and context

specific circumstances. These steps need to take into account information provided by climate risk

194 For example, this could be expressed in terms of reduction of loss of life and economic damages caused by climate

change

Understood as requirement to consider the possible risks of the decisions under future climatic conditions, with the

reference global warming trajectory as a baseline. 196 70% of the OPC respondents were in favour of identifying risk owners 197 70% of the OPC respondents were in favour of defining a common climate baseline trajectory 198 As described in the Tool 14 of the Better Regulation Toolbox

41

assessments, other sectoral/policy evidence and latest available science. The decisions will also

be informed by available fiscal space and other prevailing priorities.

7. Common parameters for progress monitoring and assessment to provide feedback on the

efficacy of ongoing climate resilience and adaptation actions, and a basis for learning and

improving.

The above elements, accompanied by the climate resilience tools and solutions, will address the

identified problem drivers and enable the risk owners to design and implement their policies and plan

investments and reforms. The ensure a logical progression from drivers and problems to outputs and

outcomes, each policy option presented in the next section explicitly maps onto the intervention logic

and causal linkages outlined in our Theory of Change. The analysis uses available evidence, including

on the behavioural change.

42

Figure 4: Intervention logic

5.2.1 OPTION A: Better implementation and incremental change through raised awareness,

guidance, tools and education

This policy option combines measures to act on the identified problems without changing the existing

regulatory or policy frameworks. It leverages on the informed self-interest of all actors affected by

climatic risks as a motivator and driver for action. Therefore, all actors must be equipped with the

appropriate information, support tools and non-regulatory incentives to make sound decisions on

climate resilience and preparedness. This requires improving clarity and coordination by public

authorities. Overall, this policy option introduces new, non-binding elements which provide signals

to national, sectoral and transboundary actors with responsibility for climate resilience and adaptation.

Under this option, improvements to decision-making and the integration of climate resilience across

sectoral policies and sectors will be recommended, but it would be left to the public authorities, at both

EU and Member State levels, to decide on how and when to do so.

43

Under this option, the EU and Member States could voluntarily set out climate resilience objective(s)

at EU/national level and include thematic targets from the Global Goal on Adaptation (A0) in EU and

national sectoral documents. For example, DG AGRI and a national Ministry for Agriculture could

consider integrating the thematic target for “proportion of area under management for food and

agricultural production utilising practices and technologies relevant to climate change adaptation”199

in their respective agriculture policies.

The Commission would develop guidance for both EU and Member State levels on how to identify

authorities responsible for addressing climate risks (= risk owners) (A1) and how these risk owners

could consider climate resilience in their policy and implementation choices (A2). For example, at EU

level this would mean supporting DGs on how to use EUCRA for embedding climate risks into their

sectoral risk assessments, along with providing good practices (linked to A12). Similarly at national

level, the preparation of the guidance would facilitate common understanding, as well as could be used

by national authorities in developing their measures to support sector authorities at national level.

To improve planning for current and future climate risks, the Commission would support the

development of a reference warming trajectory to guide EU decisions and actions across sectors and

could help national authorities to translate them into climate projections for national and subnational

levels (A4). Member States would be encouraged, but not obliged, to define reference warming

trajectory to guide their decisions and actions, while retaining discretion over the choice of trajectory

and its operationalisation (A3). In addition to guidance on how to use the trajectory, there would also

be guidance on how risk owners can systematically consider climate resilience in the implementation

of priority sectoral policies (A5). No simplification of existing EU-level regulatory requirements on

planning would take place.

The option also emphasises better implementation of existing EU legislation and governance

processes. The existing planning, reporting, progress monitoring and assessment provisions of the

European Climate Law and the Governance Regulation would remain unchanged. The Commission

Guidelines on NAP/NAS would be updated (A6) (e.g. with the reference warming trajectory, climate

resilience indicators) as further support for Member States for their climate resilience and adaptation

planning, while continuing with the flexibility to implement and operationalise them to suit their needs.

At the EU level, possible next EUCRAs would be carried out depending on the political needs and

preferences and would be updated and further refined as needed (A7). For planning and

implementation, two alternatives are considered at EU level: the development of a new EU climate

resilience strategy (A10a) or no new EU strategy (A10b). Union and Member State level climate

adaptation progress would continue to be assessed under the Climate Law and Governance Regulation,

on the basis of current general obligations and Member State reporting. Findings will continue to be

incorporated into the Climate Action Progress Reports and State of the Energy Union Reports under

the Governance Regulation.

Another central element of this policy option is better access to existing knowledge and decision-

support tools and sharing best practices. To support this, the repository of climate resilience knowledge

on the Climate-ADAPT platform would be enhanced (A11). Under this option, two new open-access

digital tools would be developed to provide easy to understand and use information on climate risks

and how to address them. The navigator of climate resilience tools (A12) will be an interactive,

searchable database to support and guide users exploring existing, trusted tools, covering EU, national,

199 (United Nations Framework Convention on Climate Change, 2025)

44

transboundary and subnational levels and all steps of the adaptation policy cycle. The European climate

viewer (A14) will translate the reference warming trajectory into concrete and spatially resolved

climate hazard information, for e.g. showcasing what will a 2ºC warmer world in 2050 mean in terms

of precipitation, heatwaves, etc in an EU country/region/municipality. Its main target audience are

non-expert actors involved in EU policy-making and cross-border risk management and

countries/regions which do not have appropriate climate risk tools.

As all the above actions are voluntary, public authorities at EU and national level retain the power

to assess how and when to take action, making these decisions based on improved information, and

using updated recommendations, guidance and new digital tools.

In this option, action in the private sector should emerge due to better information and awareness of

climate risks and solutions for example through sector-specific communication campaigns in

cooperation with EU umbrella organisations (A8), as well as tailored guidance to support the

integration of climate risks into sectoral European standardisation activities (A9). There are no

obligations on the private sector – but wherever the public authorities start identifying risk owners,

implementing the trajectory, improve their climate risk assessments, indirectly the risk awareness and

perception in the private sector should improve and trigger further action. For example, a construction

company receives guidance for their sector, including on how to find information about the relevant

climate risks; which trajectory is being used in the geographical areas where they are operating, and

which digital tools are at their disposal to visualise climate risks. This information is then incorporated

in their decision-making (including on investments), leading to a more anticipatory approach to climate

risk management, and incentivising the development and use of solutions (e.g. early-warning systems,

use of circular economy materials, use of anti-heat gear for outside workers), which can increase their

productivity and competitiveness because of less business interruption and higher revenue retention.

As for the population, their awareness could be improved through implementation of the Preparedness

Union Strategy chapter on population preparedness, and additional, EU-wide campaigns (A13), and

the use of free, public digital services such as the improved Climate-ADAPT platform (A11), the

navigator of climate resilience tools (A12) and the European climate viewer (A14).

Together with increased awareness, and the action taken by public and private sectors, the population’s

climate resilience should improve. As the measures under this Option rely on existing structures and

the willingness and capacity of public authorities, the private sector, and the population, they can be

expected to be implemented relatively quickly, within one to three years.(For detailed list of Option A

measures, see Annex 13)

5.2.2 OPTION B: New, essential ground rules, flexible delegation and enablers to trigger

transformative change

This policy option includes a limited set of new mandatory rules to overcome the identified, persistent

barriers to long-term, precautionary climate resilience. These rules are intended to catalyse a step

change in ambition and action by reorienting and aligning key policy and regulatory processes across

the EU and Member States, through more uniform application. It combines a targeted and

proportionate legislative proposal with a broad set of enabling and supporting measures.

Under this option, the proposed legislative framework would introduce a combination of binding

requirements complemented by voluntary actions designed to trigger systemic change across

governance levels and sectors. Even when establishing obligations, this policy option would leave

45

significant discretion to public authorities on how best to implement and operationalise these

obligations within authorities’ respective mandates.

The legislation would establish a shared climate resilience objective at Union and Member State

level (B0) to manage short, medium and long-term climate risks to strengthen climate resilience. This

includes a requirement to set corresponding sectoral objectives, and where appropriate, quantified

targets in relevant EU and national legislation, strategies, and plans based on the Global Goal on

Adaptation.

It would also introduce a reference warming trajectory, defined as expected global temperature

increases over specific time horizons (B1), which would be required to be used as a baseline for the

EU and Member States’ policy decisions that weigh the expected benefits of the proposed actions in

the context of broader constraints.

EU and Member States’ authorities would be required, through the “duty to consider” to ensure that

policies, measures and investments relevant to climate resilience take into account the resilience

objective, make use of the reference warming trajectory, and ensure that the residual climate

risks200are tolerable201 (B2) This would be supported by mandatory common parameters for

identifying risk ownership among public authorities and for assessing risk tolerance (B3). However,

the legislation will not determine neither EU nor national targets/ thresholds for tolerable risk,

as these are to be determined by each risk owner.

To ensure that public funding is efficiently and responsibly used in a way that supports minimising

vulnerability and exposure, application of the climate resilience by design principle (B4) (definition in

Annex 11) will be required. Application of climate resilience by design principle would also be

required in the policy context when reviewing relevant EU and national legislation (B5). For EU

policies broadly, this would mean using the Commission interservice mechanism/process for

attribution of risk ownership to the departments that are responsible for relevant policies and

for strengthening the climate resilience aspects. For a specific policy, such as e.g. infrastructure

planning in TEN-T, it would mean analysing (on the basis of the relevant climate risk assessment)

priority corridors through the lens of projected climate risks, assessing potential disruptions at a

system’s level and subsequently complementing (rather than replacing) the existing project-level

climate proofing requirements.

The initiative would also strengthen requirement for CRAs. For the EU level, regular EUCRAs would

be codified in the law, and both EUCRA and national CRAs would have to meet minimum

requirements (e.g. regarding frequency, scenarios, time horizons and coverage of sectors). At both

levels the CRAs would be required to use the reference warming trajectory as a baseline and consider

more adverse scenarios (B6). National assessments would also be required to address cross-border

risks, including those identified at the EU level (B7). The CRAs would identify major risks and present

these by sectors and policy areas, and would identify adaptation options for managing these risks.

To make planning and implementation more coherent, and to operationalise Article 5 of the European

Climate Law, streamlined and simplified common parameters and requirements would be set for

climate resilience planning and policies, both at EU and Member State level (B8). The current

200 Climate residual risk should be understood as the IPCC AR6 definition, consistent with the use of the residual risk

concept in the Tool 14 of the Better Regulation Toolbox. 201 The acceptability of risk should be determined by the risk owner, consistent with approach to the intolerable risks as

presented in the Tool 14 of the Better Regulation Toolbox.

46

obligation for adaptation planning under the Governance Regulationwould be simplified by removing

requirements to address adaptation from NECPs and long-term strategies. Adoption of Union and

Member State strategic plans on climate resilience, operationalising the common parameters and

requirements would be required. The proposed Member State strategic plans would function as the

equivalent of the current national adaptation strategies (NASs) and plans (NAPs) under the European

Climate Law. In result, for Member States, this single plan would replace the current NAS and NAP.

The mandatory common parameters and requirements within climate resilience planning would ensure

that respective policies consider climate risk management options in a way that residual risks

remain tolerable, identify policy risk owners and adequately address transboundary climate

risks. Mandating a dedicated or existing authority in Member States to centrally coordinate climate

resilience related policies would be proposed, while respecting the specific circumstances of Member

States and the principle of subsidiarity.

For progress monitoring and assessment, Member State reporting on climate adaptation would be

simplified, streamlined and improved under Article 19 as well as Annex VIII Part 1 of the Governance

Regulation, and through removing redundant reporting requirements under Article 17, and

streamlining others, such as the reporting on the use of the reference warming trajectories. Alignment

and use of existing processes across policy areas would be improved (B9). A streamlined framework

with a limited set of high-level indicators to assess collective progress at EU level would be

established, alongside flexibility for Member States to develop national indicator sets. Commission

would continue progress assessments under the European Climate Law and prepare regular progress

reports.

To support the obligations set by the initiative, some additional voluntary elements are foreseen in this

policy option. For e.g., guidance on how Member States could support regional and local authorities,

including on applying the principle of climate resilience by design when mobilising private finance

(B10), and digital tools. The Climate-ADAPT platform would be updated to reflect the key provisions

(B12). As in option A, a navigator of climate resilience tools (A12), a European climate viewer (A14).

The climate viewer will also support the practical implementation of the reference warming trajectory

and CRA requirements. The Commission would also be encouraged to use this tool systematically in

policy-making processes for relevant sector policies (B13).

As an illustrative example, Option B for the EU would mean that DG SANTE is the lead Commission

service for prevention, preparedness and response to climate related cross-border health threats and

emergencies like the emergence of dengue virus, West Nile Virus, chikungunya virus and other

climate-sensitive infectious diseases. DG HERA, in addition, is the Commission service responsible

for medical countermeasures. The European climate viewer would help both Commission services to

identify regions where climatic conditions can be expected to favour the establishment and

transmission of these diseases, thus supporting decision-making on prevention, preparedness and

response measures. Deciding on the cost-efficiency, appropriateness and urgency of these measures,

and on the tolerable residual risks would be left to the discretion of SANTE and HERA, subject to

their expertise and mandate. Public health, including the responsibility and risk ownership for climate-

related health threats, is a competence shared between the EU and its Member States.

At the same time, the risk ownership can be shared with EU-level frameworks, for example regarding

electricity security of supply. At national level, a Member State can use the European climate viewer

to visualise how a global reference warming trajectory would look like in different countries or regions

(e.g. due to the asymmetry of exposure a 2℃ reference warming trajectory can mean a 3℃ local

increase of temperature in a specific Member State and 4.5℃ in another). The Ministry responsible

47

for energy, as the risk owner, would apply that trajectory when reviewing risk preparedness of the

power grids. Drawing on EUCRA, national and sectoral CRAs, information from the European

Network of Transmission System Operators for Electricity on transborder and regional risks, and local

data, it would then assess tolerable risk levels and steer the investments proposed by the energy system

operators accordingly – for example, whether to install a new power grid in a flood-prone area where

costs are lower, accept higher future risk, or to invest more upfront in a lower-risk location.

In this option, no obligations are imposed on the private sector. However, there would be guidance

on how to voluntarily apply key public-sector concepts, such as the reference warming trajectory or

the principle of climate resilience by design (B11). To align with the latter, requests would be made to

European Standardisation Organisations to climate-proof sectoral standards, covering both physical

components and design processes202. This would introduce indirect compliance requirements for

private actors to adhere to these standards, notably when related to harmonised standards203.

The obligations imposed on public authorities (e.g. risk ownership, integration of climate resilience

across sectors/ policies, use of the trajectory) are expected to have triggering effects on private entities,

as they will want to align their decision-making with the EU and national levels. The OPC has showed

strong demand for clarity on the public approach, to signal direction for private sector. As policies

would increasingly address climate risks and the information will be more accessible through the

navigator and climate viewer, the private sector can use those to better inform their own decisions and

investments, manage their own climate risks, remain competitive and deploy climate resilient

solutions.

As in Option A, the population awareness and empowerment to manage climate risks would be done

through campaigns across the EU (A13), and the access to the digital tools. Combined with the more

systemic action by public authorities, triggered by the obligations in the law, and subsequent shifts in

the private sector, public trust could increase, and catalyse broader awareness and overall climate

resilience in the population.

Under this Option, certain measures are voluntary and other are mandatory. The voluntary measures

could be implemented relatively quickly, while the effects of the mandatory measures would likely

only start to materialise after the entry into force of the legislation, which could be three to six years.

(For detailed list of Policy option B measures, see Annex 13)

5.2.3 OPTION C. Comprehensive central rule-setting and oversight for immediate and uniform

application across sectors

This policy option would result in a comprehensive and fully harmonised policy framework at Union

level, with a strong compliance mechanism with possible penalties. A legislative proposal would

introduce an extensive set of binding provisions, to be applied consistently across all sectors and

levels of governance. It entails high degree of harmonisation and synchronisation of horizontal and

sectoral climate resilience related policies and actions at EU and Member State levels, with the

Commission playing a central role as coordinator, supervisor and enforcer. Both the European Climate

Law and Governance Regulation would be amended.

202 A standardisation request by the Commission to ESOs is based on the Standardization regulation and is once accepted

by the ESO considered as a contract that is binding for both parties. 203 (European Commission. DG GROW, 2026)

48

The legislation would establish legally binding climate resilience objectives and targets for both the

EU and Member States (C0).

To operationalise these objectives and targets, the law would also introduce the following obligations.

For the EU, the establishment of a reference warming trajectory as in (B1). The law would set up

common minimum requirements for Member States to translate the trajectory into nationally relevant

climate projections (C1). The Commission would hold a central role in steering this process,

coordinating scientific bodies and Member State authorities to produce consistent European climate

projections aligned with the trajectory (C2). EU and Member State public authorities would be under

a strict obligation to align all relevant policies, measures, and investments with the climate resilience

objectives and the reference warming trajectory, ensuring the lowest possible level of residual climate

risk (C3).

The law would define risk ownership attribution process and establish detailed, mandatory parameters

for assessing the tolerance of residual risks for both EU and Member State public authorities (C4).

Together with the obligation to apply the principle of climate resilience by design in public funding

(as in B4), and requiring Member States to support regional and local authorities in mobilising private

finance for resilience investments (C5), there would be a more uniform application and integration of

climate resilience across sectors, policies at both EU and national levels. For the Commission, the

current climate adaptation tool would be upgraded into a detailed, mandatory climate resilience check

within the Better Regulation toolbox (C20). A specific example would be the Tool 14 regarding risk

assessments, that already refers to climate risks and related aspects: a clear reference to the use of the

reference warming trajectory, the use of the viewer, and the use of EUCRA and other risk assessments

would be included. This would allow for all services to act in the same context and increase policy

coherence.

Under this policy option, once the law enters into force, existing EU sectoral legislation and policies

would need to be revised immediately to embed the climate resilience by design principle (C6).

Following those sectoral provisions, they would then be translated for example in the European

infrastructure design and equipment standards managed by the standardisation organisations.

The law would also introduce harmonised, mandatory methodologies for EU and national CRAs (C8).

Roles for EU, national and sectoral assessments would be clearly defined in the law, to ensure

alignment and coherence across governance levels, sectors and policies (C9). At the EU level, besides

EUCRA becoming a regular exercise enshrined in the law (as in B6), it would be legally tasked to

identify inconsistencies between national CRAs regarding transboundary risks, and to propose

approaches to Member States on how to improve coordination (C10).

Planning and implementation would also follow a more harmonised and standardised approach. The

2023 Commission Guidelines on NAP/NAS would be upgraded to meet the new obligations imposed

by the law, and its implementation would be assessed (C11). In addition to the common parameters

and requirements for EU and Member States climate resilience planning (as in B8), the law would also

impose an obligation to explicitly evaluate the tolerance of residual risks in the assessment of climate

risk management options (C12).

For the Commission, all relevant policy sectors and services would be legally required to develop and

implement dedicated sectoral or thematic strategies based on a common methodology (C13). For

Member States, there would also be a requirement in the law to assign specific obligations to

subnational authorities, such as the preparation of local climate vulnerability and risk plans, and the

submission of local CRAs to inform national planning processes (C14).

49

For progress monitoring and assessment, the law would establish a fully harmonised system, which

would cover EU, national and subnational levels and integrate data from across sectors (C15). To be

able to meet with the climate resilience objectives at EU and Member State levels, a mandatory set of

common indicators for EU and Member States would be enshrined in the law, with mandatory

reporting to support a robust assessment of collective progress(C16). Assessment provisions of the

European Climate Law and Governance Regulation would be stepped up, requiring more detailed

reporting from Member States and Commission progress reports and recommendations.

At the EU level, the Climate-ADAPT platform would become the centralised, mandatory platform

supporting the implementation, monitoring and compliance with the law (C17), and there would be an

obligation for the Commission to systematically use the European climate viewer in all planning and

policy-making processes (C18). For Member States, the law would introduce an obligation for them

to integrate common climate resilience indicators into their public national digital tools (C19).

For example, at the EU level it could mean the following: DG MOVE is the risk owner for transport

infrastructure and has to apply the obligations set up by the law. The DG would be required to develop

and implement a transport climate resilience strategy, based on the common EU methodology, and

incorporating the EU designated reference warming trajectory. It would have to revise the TEN-T

regulation, to ensure it would include the trajectory, the duty to consider climate risks, and the

obligation to embed the climate resilience by design. When doing this legislative revision, DG MOVE

would have to use the European climate viewer to meet with the climate resilience check in the Better

Regulation Toolbox. As risk owner, DG MOVE would also be legally responsible for ensuring that

European infrastructure design and equipment standards (managed via standardisation organisations)

are updated to guarantee the lowest possible level of residual climate risk for European infrastructure.

In this option, there is a direct obligation imposed by the law to the private sector. As sectoral

legislations need to be revised at both EU and national levels (C6), these would impose a direct

binding legal “duty to consider” climate resilience for private entities acting in those sectors/areas

(C7). While the European infrastructure design and equipment standards updates follow the revised

legislations, an indirect obligation would stem for the private sector, which would translate the

principle of climate resilience by design into market requirements.

As obligations are imposed on public authorities (including at subnational level) and to the private

sector, a consequent, more systemic improvement of the population’s awareness of climate risks and

on solutions to increase their climate resilience can be expected.

The implementation of this Option measures would likely only begin after at least six years, as it

involves revisions to multiple pieces of legislation and introduces new obligations for both the public

and private sectors. (For detailed list of Policy Option C measures, see Annex 13)

5.3 Options discarded at an early stage

Several policy options and measures considered during the preparation of this initiative were assessed

early to be disproportionate, not feasible in the current policy context, insufficiently aligned with the

objectives, or not delivering commensurate added value:

• Replacing current national, regional and local climate adaptation policies with a single European

climate resilience law/framework – as decisions are often local or embedded in sector decisions,

thus need to reflect the local value choices about tolerable levels of risk to be democratically

50

viable. Shifting responsibility to EU level would infringe the subsidiarity principle and lead to

reduced effectiveness and efficiency.

• The creation of a large-scale, ring-fenced EU climate resilience fund to accelerate investment -

while it could provide strong financial support and visibility to climate resilience and adaptation

efforts, it was discarded due to concerns regarding feasibility, political acceptability and

proportionality, including overlaps with existing and planned EU funding instruments.

• Measures to impose binding obligations on private sector actors, such as carrying out climate risk

assessments, prepare risk management plans, or disclose specific climate resilience metrics - while

potentially impactful, they would require substantial amendments to existing legislative

frameworks (e.g. corporate reporting and due diligence rules) and go beyond the scope of this

initiative.

• Binding obligations at regional and local level, including requirements for regions and local

authorities to develop comprehensive climate resilience and adaptation frameworks, conduct

climate risk assessments, and report regularly on implementation – this option was discarded on

the grounds of subsidiarity and proportionality, as it would entail significant intervention in

national governance structures and could impose disproportionate administrative burdens on local

authorities, particularly in lower-capacity regions.

• The establishment of a comprehensive progress monitoring and assessment system covering EU

institutions, Member States, regional and local authorities and the private sector - although such a

system could enhance transparency and accountability, it was discarded due to the administrative

burden it would impose across governance levels and sectors, and which was assessed

disproportionate to the expected benefits.

6 WHAT ARE THE IMPACTS OF THE POLICY OPTIONS?

The assessment suggests that each of the three policy options, to varying degrees, can address the

problem drivers. The intervention logic presented in Chapter 5 and Figure 4describe the expected

channels how the measures contribute to achieving specific objectives, and how the specific objectives

contribute to addressing the overall objective of harmonising preparedness to climate impacts and at

the same time reducing the fragmentation of preparedness across the EU economy and society. The

policy options are designed to help reduce the projected economic, social and environmental losses

associated with climate change.

Key constraints in assessing and comparing the impacts of the policy options are linked to the

uncertainties in projected futures, notably regarding climatic impacts, policy developments and

implementation across sectors both at EU and Member States’ level. Another major constraint is the

indirect impact channel between the measures addressing problem drivers and the expected

reductions in vulnerability and exposures to climatic risks, which is also delayed. It presents a

difficulty notably for quantifying the effects of the proposed three policy options, which would

materialise often indirectly and over time, through induced changes in public governance and

overall decision-making, investment behaviour, and the action by businesses and the population. Also,

separating the effects of individual measures from their combined overall impact is difficult i.e. the

sum can be expected to be larger than its parts.

The projected climatic futures and their associated socio-economic losses are subject to a high degree

of uncertainty and variability, but are considered to be subject to systemic, structural underestimation,

as explained in Chapter 2 and Annexes 8 and 12. Recorded extreme climate-related events and socio-

51

economic impacts have increased in scale and frequency over the past decades. Model-based estimates

of economic impacts have tended to be conservative as they do not capture the full range of damages

or their cascades and compounding between sectors and regions. The climate tipping points are

typically not modelled at all because of their complexity and uncertainty. As such, the potential

benefits of avoided damages in the assessment are also conservative and likely to be underestimates.

Regarding policy developments, there is limited direct scientific evidence, and for the purposes of

the assessment they are considered to continue as currently set. The Chapter 5.1 baseline is based on

evidence (including EUCRA) that considers future broad trends, but assumes policy continuity, not a

qualitative, structural improvement in how climate risks are addressed. As such, the future policies are

considered to be neutral, which conceptually isolates the benefits of the policy options considered. The

broad logical assumption is that if policies dealing with vulnerabilities and exposures remain the same,

while the climatic hazards increase, then vulnerabilities and exposures increase. This assumption is

made inter alia in the EUCRA assessment which concluded that policies are not keeping pace with the

increasing hazards.

Reducing vulnerabilities to the current or expected impacts of climate change is done through climate

change adaptation. The cost of adaptation can be assessed through several measures. One is the total

expenditure dedicated to adaptation. Another one is the total investment needs, which refers to the

level of investment required to implement all the measures described in a given adaptation plan

(national, subnational, sectoral or other), where tagging the cost added because of the adaptation

objectives is often difficult to assess. Actual spending consists of the expenditure mobilised for

adaptation measures and tracked and categorised accordingly by governments, either annually or

cumulatively since the beginning of the planning period.

When it comes to quantification, the benefits of adaptation are commonly assessed by calculating

avoided losses, i.e. considering the avoided direct and indirect damage to infrastructure and assets and

the avoided deaths and well-being losses, because adaptation measures mostly serve to maintain

existing value, rather than generating new value. Such benefits are difficult to quantify for several

reasons. Most importantly, accounting for losses avoided because of adaptation measures is

inherently counterfactual in nature. As comparing the impacts of an event on two very similar assets

in the same location is near impossible, benefits need to be estimated or inferred on the basis of

portfolio-level losses experienced in a given event. Adaptation is highly context-specific, responding

to local hazards, levels of exposure, and vulnerability factors – and adaptation needs may shift over

time in response to climate change. The benefits of adaptation measures can be difficult to disentangle

from other factors. In some cases, economically beneficial adaptation measures may already be being

taken – but they may not be identified as ‘adaptation’ per se, since they are part of another project.

Finally, the severity of physical impacts is one of the factors determining whether adaptation measures

result in benefits.

The initiative addressed most of the costs of adaptation and all of the benefits of adaptation

indirectly. Since it does not prescribe or determine individual adaptation decisions, it would not be

sound nor feasible to assume specific implementation decisions across the range of actors. Therefore,

for the purposes of assessing the Options in the impact assessment, macro-assessments and

sectoral assessments are used to act as EU-wide proxies for benefits of adaptation. For estimating

approximative differences between Options, behavioural evidence regarding efficiency and

effectiveness of different governance approaches is used.

The benefits of adaptation also capture the effects on the local economy and the ancillary impacts of

adaptation. These include reducing future risks, improving the productivity of unaffected resources

52

and people, boosting innovation by seeking solutions amid new challenges, increasing the

environmental benefits and improving ecosystem services. The ancillary impacts of adaptation can be

either positive (co-benefits) or negative (maladaptation) and may, or may not, include cascading

effects. Co-benefits of adaptation include the positive effects on biodiversity, air quality, water

management, greenhouse gas emission reductions, and health and well-being. The benefits of

adaptation in terms of both climate extremes and slow-onset events — lowering climate change

impacts, contributing to positive effects on the local economy and having other positive ancillary

impacts — is often referred to as the ‘triple dividend’, with two types of benefits being reaped

regardless of the disasters happening204.

Figure 5: The ‘Triple Dividend’ concept205

For the reasons mentioned above, it is difficult to quantify avoided losses and benefits of adaptation

at a whole economy level. Therefore, costs and benefits of the individual measures have been mainly

characterised in a qualitative way. Whenever possible, quantified costs and benefits are ascribed

to measures and the policy options or examples of similar measures and their efficacy provided.

Notably, the monetised administrative burden of the envisaged measures was estimated using the

Standard Cost Model. Also, each individual measure has been grouped for assessment within its

broader policy option cohort, while some measures received particular focus. Estimating the precise

contribution of each policy option to improved EU resilience and overall preparedness is not

possible, but illustrative examples (national, regional) are provided wherever available.

Climate impacts will affect all economic sectors. Climate hazard exposure across a sample of 70

investment grade European companies is projected to rise about 23% from the 2020s to the 2050s.206

204 (European Environment Agency, 2023; Global Commission on Adaptation, 2019) 205 (European Environment Agency, 2026e) 206 (S&P Global, 2026)

53

Sectoral climate losses outlined in chapter 2.1 (Table 1) provide a cost baseline against which

investment needs may be weighted.

Any effective climate resilience building and adaptation action is likely to avoid significant

expenditure and lost revenue. A recent report on the Assessment of Climate Adaptation Investment

needs (prepared for the Commission) examined at an EU and Member State level the investment

requirements to create resilient sectors by 2050(Table 2) provides the indicative benefit-cost-ratios for

such investment, as documented in a wide range of studies.

Table 2: Adaptation Investment Needs at EU level to 2050207,

Sector Annual investment

(EUR bn) Indicative BCR range

Infrastructure 29 Flood Prevention - 11.9:1208

Flood Barriers - 14:1209210

Coastal Protection - 15.6211

Ecosystems 21 Nature Restoration Law potential 4 – 38:1212 Floodplain &

Natural Water Retention Restoration 2.5:1213

Food sector 11.5 Reclaimed water for nutrient management – 17.02:1214

Desalinated water for irrigation – 4:1215

While BCRs are difficult to calculate across the range of

implementation measures EEA analysis of 51 farm

transitions across Europe found that climate-resilient

practices such as reduced tillage can deliver production cost

reductions of around 40%, diesel savings of around 50%,

and labour reductions of 25–30%, associated with lower

dependence on external inputs and restored soil-water

functions.216 Farm transitions nonetheless require significant

upfront investment, learning costs and can involve yield

declines before returns are realised.

Health 7 Heat-health warning systems - 11–3,700:1217

Urban green infrastructure - 1.09–2.68:1218

Community green spaces - 2.15–4.27:1219

Residential retrofitting - 1.43–1.92:1220

Economic &

Finance 0.72 BCR evidence has not been quantified at scale as risk

transfer and insurance product development returns are

207 (European Commission. DG CLIMA et al., 2026) 208 (World Bank Group, 2021a) 209 (European Environment Agency, 2023) 210 (European Commission. Joint Research Centre., 2020a) 211 (COACCH, 2019) 212 (Aubert et al., 2022) 213 (European Commission. Joint Research Centre., 2020b) 214 (Hurtado et al., 2024) 215 (Hurtado et al., 2024)216 (European Environment Agency, 2026a) 217 (European Environment Agency, 2023) 218(Johnson et al., 2021) 219 (Vačková et al., 2025) 220 (Colclough, 2021)

54

Sector Annual investment

(EUR bn) Indicative BCR range

realised indirectly through avoided fiscal costs and faster

economic recovery.

Defence & Security 1.5% of GDP.221 Gaps in data for the relationship between climate resilience,

defence and security in Europe are consistently noted in

official communications on the subject.222

Total 69

The Table 2 illustrates that the return on investment implies a strongly positive benefit-cost ratio

at scale, which is likely to carry through compiling these measures. Most sectors show an immediate

return on investment in avoiding the sectoral losses outlined above, while in some cases returns

are only realised after an initial transition period. Some - such as the high investment cost of

ecosystems - are essential to optimising climate resilience in other sectors such as labour and

agriculture through their cross sectoral adaptation and mitigation potential – mitigating flood and heat

risk, supporting water management and agriculture. More details can be found in Annex 8.

6.1 Policy Option A

Option A forms an internally coherent package which is likely to improve the information,

coordination and learning environment for climate risk management decisions across the Union,

however it will not create a consistent operational duty to act. Because of the lower (and possibly

delayed) uptake of the proposed voluntary measures, its strongest effects are therefore likely to

appear first in the form of better processes and more informed decisions in the 2030s, and only

later, and only partially, in the form of lower exposure, vulnerability and damages by 2050. Benefits

would be most visible among frontrunners and administrations with sufficient capacity, while

weaker actors may respond more slowly and to a lesser degree, so uneven uptake remains a defining

feature of the option. It would be expected to provide quicker change than under the baseline in some

areas, but does not guarantee that advised anticipatory approach, precautionary changes in policy and

investment approaches are implemented evenly and on necessary scale across Member States and other

actors.

EU added value

The positive impact of option A stems from improving the enabling environment for both public

and private actors. Better information and guidance coordinated at EU level would support more

efficient prioritisation of resilience measures and investment decisions, helping to reduce some

avoidable losses and inefficiencies by 2050. By defining climate resilience building and adaptation

needs, roles and responsibilities based on evidence and targets, the EU added value lies in

providing a common framing of risk ownership and an enhanced sense of duty to consider

climate risks. In terms of the harmonisation of climate resilience and preparedness, this would be an

221 While this figure relates to resilience more broadly than in a climate context and is the agreed target of partners rather

than specifically the EU, it is a useful proxy for this exercise: (NATO, 2025) 222 (European Commission. Joint Research Centre., 2023)

55

improvement over the baseline, especially in areas where access to information and the adaptive

capacity are limited because of uncertainty, lack of knowledge or lack of practical methods.223

Effectiveness

Option A is moderately effective, mainly because it can trigger action at a low formal burden,

however its overall impacts depend heavily on voluntary uptake. Voluntary approaches tend to be most

effective among already aware and motivated actors, while less-engaged groups are harder to reach

and typically require additional support, incentives, and clear implementation pathways to convert

knowledge into behavioural change.224 The strongest effect of the Option A is likely to be at

Commission level, where it is plausible that horizontal work on defining risk owners and organising

capacity-building could be undertaken even without binding obligations. It can also be expected to

improve administrative clarity in some Member States, especially those that already have relatively

advanced climate adaptation frameworks and would have better basis and capacity to use the

recommendation to further clarify horizontal and vertical responsibilities. This could however

potentially widen further the differences in implementation across Member States and increase

the fragmentation of preparedness as the ones that already have relatively better capacity would be

more likely to adopt the voluntary measures225. The positive impact of better information provision

should not be understated. A key driver of the failure of effective German response to the 2021

floods around the city of Cologne and the ensuing high death toll were related to issuing and

understanding warnings, and a lack of information and data exchange between municipalities.226 Even

under voluntary schemes the provision of greater information is likely, in some cases, to increase

climate resilience and lend to an anticipatory rather than a reactive attitude to climate hazards.

The effectiveness of Option A is lower in those Member States where climate adaptation

governance and adaptive capacity remain weak. Under the baseline, Member States differ

substantially in legal requirements, systemic risk approaches, and coordination capacity, and while

many policies are co-owned, there is no common formula for attribution of risk ownership, either

across sectors within Member States or between the EU and Member States. Because Option A only

recommends action, some Member States might either delay or partially engage, meaning that

fragmentation in risk ownership, accountability and uptake would persist. The ESABCC explicitly

states that the overall gaps in governance cannot be bridged by voluntary actions, like the ones

proposed in EU-level strategies alone, such as the EU Adaptation Strategy or the Preparedness Union

Strategy227. It is likely that capacity constraints are a central determinant of outcomes. The European

Environment Agency (EEA) notes that insufficient local capacity, limited funding, weak tools and

unclear roles remain common barriers across Europe.228 While Option A improves awareness,

guidance and knowledge exchange, it only partially corrects the baseline problem of unclear risk

ownership and provides weak integration of climate risk into decisions in the medium to long-term.

223 (Runhaar et al., 2018) 224 (Davids et al., 2021) 225 (Davids et al., 2021; Maidl et al., 2015) 226 (Fekete et al., 2021) 227 (European Scientific Advisory Board on Climate Change, 2026) 228 (European Environment Agency, 2025f)

56

The benefits of the supporting elements are also likely to be overall positive but uneven. A capacity-

building and knowledge-sharing action plan through the improvement of Climate-ADAPT could be

useful, especially for lower-capacity regional and local authorities, by reducing transaction costs and

improving access to methodologies and examples. The provision of the navigator of existing tools and

the European climate viewer will improve access to high-quality and policy-relevant climate resilience

tools and enhance the understanding of future climate conditions across Europe for non-expert users.

One example of the practical success of an information tool is the Klimaateffectatlas229, used by most

of Dutch local authorities, water bodies and provinces (80%) for their required risk assessments, and

providing building-level data source for financial and real estate sectors for the Corporate

Sustainability Reporting Directive (CSRD) and EU taxonomy obligations. A just resilience guidance

could also improve policy framing. While these measures can increase awareness, knowledge and

preparedness, evidence suggests that information and communication alone are rarely sufficient to

drive behavioural or institutional change unless they are accompanied by practical support, resources

and clear pathways for implementation230, to overcome entrenched sectoral silos or weak national

prioritisation. Therefore, it seems unlikely that they would overcome the fragmentation of

preparedness in the Member States.

Option A is also unlikely to keep pace with accelerating climate risks. Uneven and delayed

climate resilience building and adaptation tends to increase eventual economic costs and narrow

available adaptation options. While Option A may improve implementation among willing and

capable actors, it would not ensure EU-wide convergence in methodologies, baselines, planning or of

implementation, but rather lead to further fragmentation and less coherence. Investment is likely to

be mobilised by greater information in those Member States with the most capacity to do so. As

a result, even if there would be progress, in the long-term it would remain fragmented across Member

States and across sectors, failing to address systemic risks and limiting the climate resilience gains.

Overall, A is likely to deliver incremental governance improvements, but not a consistent Union-

wide shift in common understanding of future climate, clear allocation of risk ownership and

harmonisation of preparedness.

Cost-efficiency

Table 3: Overview of costs/benefits for Option A

EU level MS level

Main

direct

costs

• One-off coordination/support studies likely <

EUR 0.5 million;

• Climate Resilience Navigator ~EUR 50

000/year;

• European Climate Viewer ~EUR 30,000/year;

• Possible capacity-building support

benchmarked ~EUR 10 million/year (Mission

Adaptation)

• Update of national CRA and NAS/NAP likely < EUR

1 million per MS

• No additional/new mandatory reporting or compliance

costs.

• Large share of avoidable climate losses remains under

baseline trajectory.

229 (Climate Adaptation Services (CAS), 2026) 230 (Hine et al., 2016; Márquez-García et al., 2018; McLoughlin et al., 2023a; Weyrich et al., 2020)

57

EU level MS level

Main

benefits

• Improved EU-wide access to climate risk

information, methodologies and existing tools

• Stronger knowledge-sharing

• MSs who are frontrunners and take earlier voluntary

action: improved preparedness and investment

decisions; resilience investments with estimated

BCRs of 1.6–5.7; flood warning systems may reduce

infrastructure damage by up to 25%; heatwave

warning systems show average BCR of 131; wildfire

decision-support systems BCRs of 6–39.

Option A is likely to be cost-efficient in narrow budgetary terms, because it has low direct

implementation costs. At EU level, the main direct costs are limited one-off coordination and

guidance costs. Here the additional costs would depend on the extent to which the work would be

externally contracted. If it is, the one-off costs of procurement contracts would likely not exceed

half a million euro231. The cost of maintenance of the navigator of existing climate resilience tools is

estimated to be approx. EUR 50,000 per year, including staff costs, such as desk review for additional

and review of tools, updating the database and responding to user requests. For the European climate

viewer it is approximately EUR 30,000 per year, which covers EUR 10,000 for user support, EUR

10,000 for technical maintenance and EUR 10,000 for data curation and documentation.

In terms of capacity-building, if implemented through an existing support vehicle such as e.g. the

Mission Adaptation platform, costs could remain moderate relative to the potential benefits. The

current Mission Adaptation budget dedicated to capacity-building for subnational authorities is about

EUR 10 million per year, which provides a practical upper benchmark for a substantial EU

support mechanism. For this level of cost, the measure could reduce transaction costs for subnational

authorities, spread good practice, and accelerate action in frontrunner jurisdictions. For those who are

yet to take action, costs will increase as impacts become more frequent, further increasing the

fragmentation of preparedness across territories. However, the Mission Adaptation has been launched

as a decadal effort in 2021, therefore any extension or replacement after 2030 is uncertain and, if it

happens, it will entail additional cost.

At Member State level, additional costs would arise only where governments actively choose to

undertake risk owner mapping and governance clarification. There is not a lot of available data, but

assuming a Member State would update their national CRA and NAS/NAP, costs could be below

EUR 1 million per country232, if supported by external studies.

Option A does not introduce any new planning, progress monitoring, or assessment or mandatory

indicator policy measure. Therefore, no specific related costs are expected to arise. Savings from better

informed policy choices would however remain untapped.

Option A is only moderately cost-efficient in a wider economic sense, because the low

implementation cost is matched by relatively limited and uneven delivery. While resilience

investments often have high returns under Option A only part of this potential will be realised because

the measures offer support but do not require authorities to act, therefore resulting in an uneven and

231 Based on the assumption that a procurement contract would entail a study to identify risk ownership and support to

developing guidance and action plans, at a contract value of EUR 500,000. 232 For e.g. Spain national CRA (EUR 355,500; (Explorador de Gobierto Contratación, 2023))and Estonia (EUR 426,929;

(The EEA and Norway Grants, 2026))

58

only partial uptake. The main economic value of this policy option lies in reducing transaction

costs, improving project preparation and encouraging earlier voluntary action.

However, because of a voluntary nature and related lower uptake and/or lag in the implementation, a

large share of potentially avoidable losses would remain on the baseline course/path.

Furthermore, while benefits may accrue to some early and advanced adopters in a scenario where

adaptation pathways diverge across Europe, modelling conducted as part of the Debt Sustainability

Monitor shows that a non-uniform approach may lead to higher macroeconomic and fiscal costs

overall.233 The local/regional variation of adaptive capacity is also likely to lead to inefficiencies. A

study of the climate adaptation plans in over 200 urban areas in Europe showed that inaction in some

areas is detrimental to overall national adaptation actions and consequently to European

adaptation as a whole.234 These results have been amplified by more recent studies which show that

funding is uneven for climate adaptation both across European regions and the urban-rural divide.235

An uneven implementation poses the risk that some of the weak links will not be addressed, therefore

the systemic risks related to climate impacts may persist. The limitations of the “opt-in” approach

Option A would not be able to overcome the systemic element of climate impacts.

Furthermore, this option is likely to produce modest competitiveness indirect benefits through

clearer signalling and voluntary action, however these gains would remain limited. By providing

signals, through action taken by public authorities, to support the development of a resilience solutions

market, Option A would likely stimulate some growth of the EU share in what is expected to be a

global USD 4 trillion dollar market by 2050.236 However, while better able actors are likely to seize

upon the advantages to competitiveness provided by better information and guidance, the lack of

binding rules mean that growth in this sector in the EU will be piecemeal, restricted to regions most

able to engage with resilience solutions, and private sector actors which either have very high risk

profiles, or are already leaders in the field. Very large protection and financing gaps would remain.

Somewhat better project preparation and awareness of existing tools could marginally improve uptake

of available funding, therefore Option A represents limited maximisation of the significant cost and

investment opportunity offered by stimulating a resilience solutions market as evidenced for

example by the estimate rate of return on flood defence.237

Flood risk management accounts for the most extensively analysed set of adaptation investments in

Europe, and consistently demonstrates high returns across a range of intervention types and

geographies. JRC PESETA IV modelling, which is the most comprehensive EU-scale cost-benefit

analysis of flood adaptation, projects that without action, annual river flood losses in the EU will grow

from around EUR 7.8 billion today to nearly EUR 50 billion by 2100 under a 3°C scenario.

On coastal flooding, PESETA IV shows that optimised dyke improvements along Europe's coastlines

could reduce projected 2100 annual coastal flood damages — which could otherwise reach EUR 240

billion under unmitigated climate change — by around 89–90%. This represents avoidance of between

EUR 97 billion and EUR 216 billion in annual damages relative to a high-emissions scenario. Work

233 (European Commission. DG ECFIN, 2026) 234 (Reckien et al., 2014) 235 (Venner, Olazabal et al., 2025) 236 (World Economic Forum, 2025) 237 in some cases, the benefit-to-cost ratio (BCR) of flood protection investments can reach as high as 120, meaning every

dollar invested generates USD 120 in benefits (Flood Control Interantional, 2025).

59

conducted by COAACH to 2050 complements these findings.238 Table 4 below shows the estimated

damage mitigation of adaptation work on coastal and river flood damage as well as damage caused to

transport infrastructure out to 2050:

Damage

Cost of

Adaptation

Damage Mitigation by

Adaptation

Damage Reduction

(%) BCR

Coastal Flooding EUR 115 - 310 B EUR 14-17 B EUR 87 - 266 B 76 - 86% 6.2 - 15.6:1

River Flooding EUR 11 -18 EUR 6.4 - 10.3 B 58%

Transport

EUR 954 -1147

M EUR 562 - 645 M 56 - 59%

Table 4: Estimated damage mitigation of adaptation work

Although the benefit-cost ratio modelling is limited to coastal flooding due to their estimation of the

required costs, the potential for damage mitigation under what COAACH describes as “optimum”

adaptation is considerable, consistently above 50% for these three areas and about 75% for coastal

flooding damage specifically. According to this estimation, Option A risks to be below the ‘optimum’

adaptation level.

Targeted dyke strengthening and retention reservoir investment shows positive benefit-cost ratios

across the majority of EU NUTS2 regions under a 2°C scenario. Country and city-level evidence

confirm this picture across different infrastructure types and investment scales:

• Portugal (flood prevention and nature-based water management): BCR up to 11.9,

returning nearly EUR 12 in benefits per EUR 1 invested. 239

• Vega Baja del Segura, Alicante (Spain): An integrated flood protection plan recovered

EUR 265 million in land productivity and avoided EUR 620 million in property damage. 240

• Lublin region, Poland (decentralised rainwater solutions): BCR of 1.20–1.88 for dual

installations and infiltration tunnels in commercial buildings.241

The case studies here illustrate what planned, well-designed flood protection delivers relative to its

cost, as an example of direct measures from the initiative and follow-up intervention. Climate

resilience by design is the primary mechanism through which these returns are systematically

captured (direct measure); without a duty to consider climate risk (direct measure) in infrastructure

planning decisions, investment defaults toward reactive post-disaster repair, where the same evidence

base shows costs are orders of magnitude higher.

The macroeconomic impacts will be uneven across sectors, regions, and Member States. France

for example will need to increase its annual investment against climate change to EUR 127 billion by

2050, while Spain will need to input EUR 56 billion per year by the end of the same period.242 Option

A may lead to less than optimal return on investment for these expenditures and consequently to

238 (COACCH, 2019) 239 (World Bank Group, 2021a) 240 (Ortuño et al., 2022) 241 (Iwanek et al., 2023) 242 (European Commission. DG ECFIN et al., 2025)

60

inefficiencies in climate resilience and adaptation when policies do not align across transboundary

risks.

The benefits of limited intervention presented by the “opt-in” position of A are counterbalanced by the

unrealised cost-saving potential represented by operationalised climate resilience and adaptation in

Member States and sectors where adaptation is low priority. This not only has effects for Member

States themselves but also knock-on effects for cross-border regions, transnational sectors and shared

resources which limit the realised potential of climate adaptation efforts elsewhere.

Sectoral examples of the use of direct measures from the intervention

Agriculture and forestry: Better uptake of climate information, advisory services and planning

guidance could modestly improve crop choice, farm management and drought preparedness in

willing regions.243 Decision support tools for and wildfire risk alerting systems may yield BCRs

ranging from 6 to 39.244 However, the substantial EU-level work on wildfire prevention know-how

and early warnings has had limited impact, as demonstrated by the catastrophic 2025 wildfire

season.245 The Communication on Integrated Wildfire Risk Management246 outlined an integrated

approach to wildfire risk management and identified measures to support its implementation at both

the EU and national level.Similarly, forest owners’ awareness about climate risks cannot be

expected to result in tangible adaptation actions.247

Health and wellbeing: Option A could modestly improve preparedness for heat through better

awareness, earlier warning, and wider use of available planning tools248. The World Bank found

heatwave early warnings to provide a mean benefit-cost-ratio of 131 (range of 48– 246).249

Infrastructure and the built environment: Relative to the baseline EUCRA range of around EUR

13-29 billion expected annual economic damage by the 2050, Option A could plausibly moderate

losses by some percentage points over time. Better information and early warning systems for

flooding could limit infrastructure and built environment damage by as much as 25%.250

Finance and insurance: Better information, clearer signalling and somewhat earlier voluntary

action could help avoid a limited share of maladaptation and improve risk pricing and project

selection in some sectors.251 This would mean a modest reduction in avoidable fiscal pressure

relative to the baseline, but not enough to change the overall severity category or the broad risk of

widening divergence between better-prepared and less-prepared regions.

243 (European Commission. Joint Research Centre. Institute for Environment and Sustainability., 2012) 244 (World Bank Group, 2024) 245 (European Commission. DG ECHO, 2026b) 246 (European Commission, 2026a) 247 (Sousa-Silva et al., 2018) 248 (European Commission, 2025i) 249 (World Bank Group, 2021b) 250 (Commission of the European Union. Joint Research Centre., 2015) 251 (OECD, 2024a)

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Distributional effects

Social impacts are likely to be negative overall. In the absence of stronger incentives, obligations or

support mechanisms, lower-capacity households, SMEs, municipalities and lagging regions are

less likely to prioritise resilience, increasing the risk of reduced social protection and widening

disparities over time. Significant cross-country variation is expected. The share of citizens who remain

unable to act on risk information would likely stay high or unchanged.

In terms of environmental impacts, option A would likely improve only modestly compared to

the baseline, without significantly altering ongoing ecosystem degradation or strengthening natural

buffering capacity. Option A could help some authorities and land managers take more climate-

informed decisions and better account for ecosystem vulnerabilities, transboundary effects and

maladaptation risks. This would improve ecosystems which are degrading partly due to poor

information or weak integration into planning and permitting. However, as this option does not impose

any new obligations, and systemic change would be marginal, therefore broader trend of environmental

degradation would not be reversed. In the long term, environmental impacts would depend on whether

climate resilience is integrated effectively across sectors in a coherent way – otherwise, irreversible

environmental losses would still remain.

6.2 Policy Option B

Option B would result in a more disciplined, harmonised and comparable governance cycle that

begins to shape public and private decisions more systematically, with the most important

downstream reductions in exposure and vulnerability emerging progressively rather than immediately.

Because Option B is the first package that establishes binding ground rules for how climate risks,

residual risks, and climate resilience by design are treated in public decision-making, its mid-century

impact should be understood as materially bending the baseline expectations rather than merely

improving implementation marginally.

EU added value

Option B would reduce current fragmentation in climate resilience and preparedness while converting

the growing body of knowledge into a more harmonised and operational adaptation policy cycle that

would shape public and private decisions more systematically.

The delegated and flexible design of the option preserves the agency of Member States for local

specificities, while setting a common minimum framework for core processes. Uniform

application is likely to lead to significantly greater individual and Union level climate adaptation status,

as Member States and stakeholders can build on the learnings of early adopters and draw on common

practises. The result of this common framework of both understanding and action is an increased

efficiency and effectiveness. Reduced divergence in methods, planning, monitoring and the

promotion of a common terminology for communication would reduce duplications and contribute to

simpler, more coherent reporting to the EU and within Member States, as well as for progress

assessments. For example, the amendments to Council Directive 2011/85/EU on Requirements for

Budgetary Frameworks of the Member States, adopted as part of the revised EU Economic Governance

Framework, require EU Member States to assess and report from 2026 onwards, to the extent possible,

on (i) how the macro-fiscal risks fromclimate change may affect the medium- and long-term

sustainability of public finances (Article 9(2)(d)) – covering both the fiscal implications of climate

62

change impacts and of adaptation and mitigation efforts – and on (ii) disaster- and climate-related

contingent liabilities and the fiscal costs of disasters and climate-related shocks (Article 14(3)). The

Directive allows flexibility in the methodologies used to conduct assessments, acknowledging the

diversity of existing approaches, and differences in data availability and country-specific contexts. The

elements of the Integrated Framework, such as mandatory use of reference warming trajectory,

harmonised national climate risk assessments and the availability of climate viewer, would support the

assessments of climate change impacts on the sustainability of public finances by providing a common

analytical basis (reference warming trajectory, climate risk assessments) and better access to location-

specific data (European climate viewer).

Underlining climate resilience and adaptation through a common EU framework reduces the

information costs required to make cross-border measures effective. Minimum obligations

outlined in Option B contribute to establishing common expertise across shared landscapes, sectors

and resources. This would enable administrative synergies to be fully exploited and reduce the risk

that adaptation actions undertaken in one part of a transboundary riverine landscape is weakened by

inconsistent or contradicting actions across the border.

Option B would not erase the differences in EU and national climate resilience and adaptation policies

and risk assessments, but it would make it less plausible that weak performance would continue

undetected over time.

EU added value is strong because establishing a common duty to consider and shared parameters

helps reduce fragmentation in how authorities define and manage climate‑risks across the

Union. Member States would move from a mostly voluntary and fragmented process of climate

resilience policy development to an anticipatory, more coherent but still flexible and contextualised

process, with better informed tracking of progress. The harmonisation of the policy cycle will also

allow for exchange of information, know-how and experience between the Member States, further

underpinning the systemic and transboundary aspects of climate risk management.

Effectiveness

Option B is likely to be effective, because it changes the default expectation for public decision-

making and addresses the common failure of long-horizon risks (climate, infrastructure) not being

assigned to anyone. All Member States would need to engage in defining horizontal and vertical risk

ownership arrangements. An example of how effective a clear attribution of risk ownership can be, is

the Netherlands, where Delta Commissioner oversees the progress of the National Delta Programme,

reporting annually to Parliament, and advising the government on climate adaptation matters, either

on request or own initiative. The Commissioner owns the risk in a coordinating sense rather than a

direct operational sense, which is more appropriate for a whole-of-government challenge, and it means

that the effectiveness depends heavily on multi-actor cooperation. This model – clear risk ownership,

structured accountability, cross-sector collaboration252 – is the kind of approach the initiative seeks to

trigger.

This Option also strengthens the interaction between Member States and EU on adaptation

duties, because the allocation of responsibilities and the duty to consider would no longer depend on

voluntary alignment. Improved and streamlined progress monitoring and assessment would better

inform policy development and facilitate regular reviews and revision to drive continuous

252 (Bloemen et al., 2019)

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improvement. The option also tackles several operational gaps and fragmented approaches

simultaneously. Establishing a requirement to decide about what level of residual risks is tolerable

would improve consistency in decisions on where to adapt further and where to rely on insurance,

compensation or solidarity mechanisms. The operationalised climate resilience by design principle

would push climate resilience upstream into public spending decisions, reducing likelihood of the

future damages and vulnerability of the assets. Designing assets for resilience from the outset is

substantially less costly than retrofitting after climate-related damages – while e.g. at the

infrastructure level climate proofing the asset during construction translates into average 3% cost

increase253, the post disaster reconstruction, including structural improvements, costs on average 35%

of the cost of building a new house of the same size254. On top of this, the indirect costs of climate-

related damage include avoided displacement and debris removal, loss of business or rental income,

loss of life quality and productivity, loss of customers, supply chain delays, reduction in employment,

costs to the public health system, tax base erosion, and loss of affordable housing. The transboundary

cooperation and stakeholder consultation provisions would also support further harmonisation of

climate resilience and preparedness.

Option B would also strengthen resilience to systemic and cascading climate shocks. Improved

anticipatory governance and cross-sectoral planning would reduce fragmentation and enhance

preparedness. It would significantly lower the risk that responses are dominated by reactive crisis

management and distributional conflict, helping to preserve institutional capacity for preventive action,

adaptation finance and coordinated responses, while supporting cohesion, solidarity and the

functioning of the single market.

Option Bis expected to improve the consistency with which future climatic conditions are

reflected in investment decisions, infrastructure standards and risk management practices. It would

also contribute to stronger cross-sectoral coherence and a more systematic management of climate

risks compared to the baseline. The European climate viewer will support the uptake of the reference

warming trajectory by providing its first practical implementation, making it readily accessible to all

risk owners. Commission services are expected to be early adopters of the viewer, given their

obligation to incorporate the trajectory into policy decisions at EU scale. As shown by the

Klimaateffectatlas255 reported in Option A, digital tools gain substantial traction when they are aligned

and support compliance with regulatory obligations. A common framework for climate resilience

building and adaptation is likely to have positive effects on the overall competitiveness of the EU, as

it guarantees a baseline condition for resilience and adaptation technologies and solutions and ensures

demand for those solutions. It would also support Single Market, as Union-level standards and

minimum requirements will have a strong positive interaction with the tenets of the Single

Market and promote growth. A common framework for climate resilience and adaptation action is

likely to provide a solid foundation for innovative financial and insurance instruments that will aid the

development of adaptation actions in the private sector, even though these are not directly regulated

under Option B.256

253 (Nicolas et al., 2019) 254 (Collins et al., 2022)https://www.iccsafe.org/building-safety-journal/bsj-technical/how-much-does-resilient-housing-

cost/ 255 (Climate Adaptation Services (CAS), 2026) 256 (European Commission. DG ECFIN, 2024)

64

This option is likely to generate notable economic benefits compared to the baseline, as it would shape

public and private investment decisions. Investment in climate adaptation measures is likely to be

mobilised effectively both by greater information, harmonised adaptation policy cycle and

minimum requirements. Stable policy is essential for actors to invest. Research has already shown

how operational market architectures can for example help the EU, to translate water resilience

objectives into investable outcomes.257

Option B should reduce avoidable macroeconomic losses relative to the baseline. A cautious

assumption would be that, while climate-related losses remain in 2050, the baseline trajectory is

materially moderated. For example, where the baseline points to annual coastal flood losses of around

EUR 10.9 billion in 2050 under a moderate mitigation pathway and EUR 14.1 billion under high

emissions258, Option B could plausibly bring these down significantly if direct measures (such as

climate risk ownership, duty to consider, use of trajectory) are combined with follow-up interventions

(for example decision to build infrastructure which can withstand a certain level of water rise estimated

until 2100, based on latest scientific data). The Dutch ‘room for rivers’ programme implemented

between 2006 and 2015 reduced flood frequency and exposure, with benefits valued at around EUR 2

billion of avoided economic damage in case of breaching and around EUR 70,000 a year from reduced

flood frequency.259 In Denmark, the cloudburst flood management system to prevent surface flooding

is providing approximately a net EUR 400 million in benefits.260 The EUR 1.88 billion investment in

the Integrated Rhine Programme has been calculated to prevent future flood damages of some EUR

41 billion in the German States of Baden-Württemberg, Rhineland-Palatinate, and Hesse alone.261

The overall economic impact of reducing fragmentation presented by Option B cannot be understated:

a recent report advised that a fragmented approach to climate could lead to higher fiscal costs

overall.262

Implementation quality will matter greatly. Evidence suggests that formal duties and consultation

requirements can help shift decision-making practices, but meaningful change depends on clear

responsibilities, leadership and organisational capacity. Without these enabling conditions, there is a

risk that compliance becomes procedural rather than leading to substantive adaptation action.263 The

effect at EU level may also be smaller than at Member State level because some horizontal integration

is already emerging in the current and proposed MFF architecture. Still, Option B is likely to produce

a broader, deeper and more durable change in governance practices, with benefits compounding

over time as risks become more systemic and cross-border.

Progressively more pronounced, this change would result in lower residual damages, fewer long-

term inefficiencies, and better preservation of productivity and fiscal stability across the EU.

257 (Victoria Edwards et al., n.d.) 258 (European Commission. Joint Research Centre., 2020a) 259 (Asselman et al., 2016) 260 (European Environment Agency, 2023) 261 (Ministerium für Umwelt, Klima und Energiewirtschaft Baden-Württemberg, n.d.) 262 (European Commission. DG ECFIN, 2026) 263 (Burnside-Lawry et al., 2016; Clark et al., 2025; Wehn et al., 2015)

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Cost Efficiency

Table 5: Overview of cost/benefit for Option B

EU level MS level

Main

direct

costs

• One-off development costs for criteria,

guidance, methodologies > EUR 1 million

• Climate Resilience Navigator

~EUR 50,000/year;

• European Climate Viewer ~EUR 30,000/year;

• Policy cycle support package: EUR 4–5 million

per cycle (includes EUCRAs, development of

Union adaptation/climate resilience plan, and

improved Commission progress monitoring)

• Resilience by design public funding:

~EUR 15 billion over the MFF period

(~EUR 2 billion/year based on a 3% climate-

proofing uplift).

• Policy cycle support package : ~EUR 2–4 million per

Member State, which includes:

• national CRAs: ~ EUR 0.3 - 0.7 million per MS

• national climate resilience policy ~ EUR 0.4 - 1.2

million per Member State

• progress monitoring, assessment, evaluation ~

EUR 0.1 - 2 million per Member State

Main

benefits

• Efficiency: Limits administrative burden by

building on existing processes and reducing

duplication and fragmentation.

• Improved EU-wide access to climate risk

information, methodologies and digital tools

• Stronger knowledge-sharing

• Policy coherence: Provides clearer, uniform

market signals to investors and industry across

the EU.

• Market growth: Stimulates the EU climate

resilience technology market (global market

revenues projected to quadruple from USD 1

trillion in 2024 to USD 4 trillion by 2050)

• Better policy coherence, improved risk assessments

which support better planning and implementation at

national, transboundary and EU levels

• 4:1 benchmark BCR for resilient infrastructure,

yielding EUR 60 billion in lifetime benefits (avoided

damages/disruptions).

• SME & Public Finance resilience: Clearer risk data

improves SME investment decisions and mitigates

long-term pressure on public budgets.

Estimates of costs at EU level are based on the costs of comparable EU external contracts which,

although undertaken at times for different purposes, are considered a reasonable proxy for

estimating the likely costs of this policy Option.

The direct administrative and adjustment costs will mainly occur from integrating climate

resilience and adaptation into planning and regulatory processes, which will require analytical

capacity and procedural changes.

Option B entails some direct costs but is balanced in cost-efficiency terms. At EU level, the one-

off cost of developing common criteria, guidance, and methodologies could be estimated at more than

EUR 1 million.264

Option B seeks to align existing processes across EU sectors by building on what is already in

place, rather than creating new procedures, thus helping to address current fragmentation and

duplication. Even though some upfront costs are expected, the Option B would still aim at minimising

administrative burden and overall costs by making better use of the already established planning and

264 EUR 300,000 for EU Taxonomy Appendix C sectoral guidance (European Commission. DG ENV, 2024); EUR 630,000

for Pan-European fire safety mapping data and addressing data gaps (European Commission. DG GROW, 2019)

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reporting processes. In so far as sectoral policies are concerned, the aim would be that sectoral

departments of the Commission would consider the development and integration of relevant climate

resilience reporting and indicators in their sector governance, as relevant. While this will ensure

ownership within the sectoral policies, it also means that administrative and adjustment costs will be

impact assessed within sectoral acquis and are not directly emerging from the initiative.

Direct costs at the EU level for a full climate adaptation policy cycle support package could be

estimated at EUR 4 to 5 million per cycle. 265

Activities include an estimated EUR 2 million for future EUCRAs266 , EUR 0.5 to 1.5 million for the

preparation of a Union adaptation plan267. In addition, for the EU-level indicator set, costs would arise

on the Commission and EU agency side to support development and harmonised implementation, but

those would depend on the sets to be adopted and whether information sources are already available.

A relevant benchmark is the EEA’s Reportnet 3, the EU environmental e-reporting platform used to

collect, quality-check and process hundreds of reporting dataflows: its set-up cost was

EUR 3.5 million268, with estimated annual operation/IT costs of around EUR 1 million269. Union level

reporting and assessments would continue within the existing setup under the European Climate

Law and the Governance Regulation tailored to the Option B, and would thus mainly require

maintenance and incremental adjustments resulting from the review of the Regulation.

At national level, publicly available cost evidence is limited and uneven, as many Member States

do not publish contract values or budgets for climate adaptation policy cycle work, particularly where

tasks are delivered internally by ministries, environment agencies or research institutes. The available

evidence comes mainly from small to mid-sized Member States and may not be directly

transferable to larger ones, with more complex governance systems, federal structures or stronger

subnational responsibilities.270

Direct costs at national level for a full climate adaptation policy package can be estimated

approximately between EUR 2 million and 4 million in external technical assistance costs.271 Activities

include: national CRA procured externally between EUR 350,000 and EUR 750,000272; between

265 Excluding internal Commission and EU agency staff time 266 (European Environment Agency, 2024) 267 EUR 572,000 for the Green Public Procurement (European Commission. DG ENV, 2026); EUR 600 000 for the EU

Forest Strategy (European Commission. DG ENV, 2025b); EUR 750,000 for the Implementation of EU Water Legislation

and Water Resilience Strategy (Opća bolnica ‘Dr. Anđelko Višić’ Bjelovar, 2024); EUR 1.8 million for assistance to the

EU Nature Restoration Law and the EU Biodiversity Strategy for 2030 (European Commission. DG ENV, 2025a) 268 (Task Force on access to information, nd) 269 Based on EEA list of contracts 2021 - EEA/DIS/18/018 (EUR 1,080,000) 270 The evidence base covers the last 15 years, rather than only recent years, because up-to-date public cost data are sparse.

Older figures may not fully reflect current prices, inflation, higher analytical expectations or newer requirements. Finally,

the estimates exclude internal public-sector staff time and do not cover the cost of implementing adaptation measures. They

should therefore be read as planning estimates for technical assistance, analytical support work, IT development and policy

cycle support, rather than as full costs of adaptation action. 271 Including for e.g. establishment of a national knowledge platform, monitoring centre and additional analytical work. 272 For a standalone and comprehensive national climate risk assessment procured externally, recent EU MS evidence

suggests a defensible planning range of around € 350k - € 750k, based on Spain (EUR 355,500; (Explorador de Gobierto

Contratación, 2023)), Malta (EUR 452,540, (National Audit Office Malta, 2025)) , Belgium (EUR 500,000, (Cerac et al.,

2025)) , Netherlands (EUR 500,000, (Ministerie van Infrastructuur en Waterstaat, 2022)) and Ireland (EUR 754,627,

(TED, 2024)) .

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EUR 400,000 and 1.2 million for the development/revision of a NAP/NAS273. In terms of progress

monitoring and assessment, costs are more variable: light indicator updates or basic reporting tools

costs may range between EUR 100,000 and 300,000, while setting up a full national adaptation

monitoring system may require EUR 1 to 2 million, with annual maintenance around EUR 300,000.274

Option B would also indirectly drive additional costs (and benefits) related to possible sectoral

policy or implementation changes both at national and EU level, resulting from the consideration of

climate risks in the decisions of the risk owners. Those costs (and benefits) will be assessed in the

Impact Assessments conducted within the context of these revisions. Given that risk owners will need

to weigh the costs and benefits of adaptation measures within their policy area, only the measures

where long-term benefits outweigh costs would be taken, and therefore the outcome is expected to be

net positive.

Sectoral aspects

Next to the administrative costs, the main cost comes from the resilience-by-design element in public

funding, which would come in form of additional cost of climate-proofing when investing in built

environment. To give an illustrative example, assuming a 3% average climate-proofing cost uplift275

to 50% of the proposed EUR 2 trillion next MFF implies additional resilience investment around

EUR 15 billion over the MFF period, or about EUR 2 billion per year. Using the benchmark

benefit-cost ratio of about 4:1 for resilient infrastructure276, these indirect additional costs could

translate into roughly EUR 60 billion in lifetime benefits through avoided repair costs, fewer

disruptions, lower maintenance, longer asset life and reduced stranded-asset risk. This is emulated by

real world examples. Flood barriers installed in Prague after flooding in 2002 at a cost of EUR 146

million have been estimated to have saved more than EUR 2 billion in damage reduction.277 Meta-

analysis conducted by the JRC focusing on flood adaptation measures supports the considerable benefit

to cost ratios of adaptation investment, as the following table shows.

Table 6: Return on flood adaptation investment278

Adaptation Measure Return on Investment per EUR

Strengthening Dikes EUR 2 – EUR 2.9

Flood Water Storage EUR 2.9 – EUR 3.5

Building Protections EUR 5 .20

Option B represents not only a significant cost-saving but also an investment opportunity by

stimulating growth of a climate resilience technologies market in Europe, creating

273 The strongest direct evidence points are Estonia (EUR 426,929; (The EEA and Norway Grants, 2026)), Croatia (EUR

770,000; (Republika Hrvatska. Ministarstvo zaštite okoliša i zelene tranzicije, 2016)), Latvia (EUR 1,035,629; (The EEA

and Norway Grants, nd)), Portugal (EUR 1,200,275; (The EEA and Norway Grants, nd)) and Bulgaria (EUR 1,564,229.86;

(European Commission, nd)). 274 The best current benchmark is Finland, where updating the indicator base is estimated at EUR 250,000, while setting

up a full adaptation monitoring system is estimated at EUR 1 - 2 million with annual maintenance of about EUR 300,000

(Finsih Government, 2024). 275(OECD, 2024b) 276 (Rising et al., 2026) 277 (European Environment Agency, 2023) 278 (European Commission. Joint Research Centre., 2020c)

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competitiveness and innovation benefits. By establishing a common duty to consider climate risks (as

projected according to reference warming trajectory) across all public investment and policy decisions,

it generates long-term, predictable requirements for resilience products and services across every

Member State simultaneously. The measures included in the Framework would create, indirectly,

structural demand for resilience solutions e.g. for flood defences, heat-resilient urban cooling, early

warning systems and climate-resilient infrastructure in transport and energy sectors. Global investors

estimate that annual revenues from climate resilience solutions will more than quadruple in size

from USD 1 trillion in 2024 to USD 4 trillion by 2050.279280

While it is difficult to extract a potential European market share from these figures, there is a

clear economic logic to the European growth in this space. Annual climate-related economic loses

have reached on average EUR 45 billion since 2020.281 This creates a large adaptation investment

gap and holds out the opportunity for growth, as European firms already operating in this space

are well placed to take advantage of this gap and of the demand for climate resilience solutions.

Providing clear and uniform policy direction as contained within the Option B signals to

investors and industry that real and long-term gains are to be made within this market,

underpinned by clear policy signals. Innovative climate resilience solutions will protect businesses,

create profits for the ones providing them, strengthen Single Market and drive further competitiveness

and growth. Providing a uniform approach to climate resilience while still allowing for local

innovation, Option B maximises the potential for climate resilience technologies in the EU.

Option B will have indirect impacts on SMEs, mainly through better policy coherence, improved

information and market signals. The integration of the climate resilience by design principle into public

funding and policies is likely to shape SMEs investment decisions, improved and more coordinated

climate risks assessments will provide clearer information on sectoral and cross-sectoral risks, helping

SMEs better understand and manage their climate risks. Many adaptation measures are inherently local

and small-scale, from building renovations to local contracting for labour and infrastructure work,

energy or risk audits, or provision of tailored financial or digital products and services. This necessarily

creates opportunities for SMEs.

Option B is expected to increase indirect short-term design and compliance costs, but the balance

is likely to remain positive over time. Furthermore, improved resilience of infrastructure, public

services, health preparedness and public and private investment, would mitigate pressure on public

finances.

Option B therefore appears cost-efficient over time, because it increases near-term compliance and

investment costs, but improves the quality of expenditure and reduces future losses from maladaptation

and poorly designed assets.

279 (BloombergNEF, 2025) 280 (World Economic Forum, 2025) 281 (European Central Bank et al., 2026)

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Sectoral examples of the use of direct measures from the intervention

Agriculture and forestry: Compared with the baseline, the trajectory of avoidable losses would be

moderated. Option B could make agricultural adaptation more anticipatory and consistent, especially

in relation to crop choice, irrigation planning, drought preparedness and advisory systems. Integrated

fire risk management can strengthen fire suppression capacity even as the risk of wildfires continue

to increase. From a longer-term perspective, over a quarter of Europe was found to be suitable for

preventive land management strategies within areas of greater fire risk.282

Health and wellbeing: The broad EUCRA conclusion that heat stress becomes a critical risk by

2050 would remain, but the avoidable burden could be reduced materially. Considering the 1990-

2019 period, fully implemented heat-prevention plans (including heat-health early warning systems

and heat health action plans) might be associated with a ~25% reduction of excess deaths.283 Heat-

related mortality by 2050 could plausibly even be reduced by up to 77% compared to a baseline

trajectory in integrated contexts, as evidenced from the uptake of similar programmes in France.284

Infrastructure and the built environment: Relative to the baseline EUCRA range of around EUR

13-29 billion expected annual economic damage by the mid-term, Option B could plausibly reduce

losses by a large margin by 2050 under full implementation. Integrated flood management systems

can reduce economic and infrastructural damage by as much as 70-80%.285

Finance and insurance: Option B would reduce climate risk more systematically across the wider

economy and society and mitigate costs in insurance and financial markets. Identification of risk

ownership is in fact expected to lead to innovative insurance products which will contribute to

increased EU competitiveness.286

Distributional effects

Social outcomes are expected to improve compared to the baseline. Embedding considerations of

exposure, vulnerability and just resilience into risk assessments, policy planning, progress

monitoring and assessment, would strengthen the abilities to identify risk owners and improve the

basis for addressing distributional impacts. This would help narrow protection gaps and facilitate

targeted support for vulnerable cohorts which require it.287 While some inequalities are likely to persist,

as differences in implementation capacity across Member States and sectors may lead to uneven

outcomes, the identification of these cohorts through the identification of risk gaps is still a positive

step towards providing supports.

This would have a significant distributional effect for example on mitigation of climate driven

hydrological disasters in regions across Europe. In the absence of climate adaptation, such disasters

are expected to cause a 0.7% negative welfare change expressed in GDP under a 2℃ scenario

282 (OECD, 2026), In 2024 92% of fires were extinguished within 90 minutes in contrast to 79% in 2017 and in the context

of a growing exposure to wildfires. (Neidermeier et al., 2023) 283 (Urban et al., 2025) 284 (Callahan et al., 2025; Urban et al., 2025) 285 (Kok et al., 2005) 286 (European Commission. DG ECFIN, 2024) 287 (European Commission. Joint Research Centre., 2020c)

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regional differences can vary significantly between 0.2% and 1.8%288, primarily driven by drought.

These distributional effects are supported by and explored further by work conducted by the JRC.289

In some modelled scenarios, climate adaptation measures can reduce the annual costs of damage in

economic and human terms by 66%.290 The compounding effects of a uniformapproach to climate

resilience and adaptation means that there is potential for even greater cost saving and return on

investment across regions.

Uninsured losses across regions vary significantly with 8% of economic losses in Spain between 1980

and 2022 uninsured, while less than 1% of losses were uncovered in Ireland and Belgium.291 Parity of

approach to climate resilience building and adaptation is expected to create more equal footing

alongside innovate insurance and financial products because of the uniform framework.292

Environmental impacts would improve relative to the baseline, though not sufficiently to lead to

immediate ecosystem recovery or to prevent all deterioration. The duty to integrate the climate

resilience by design principle in public spending would support a more integrated and forward-looking

approach to ecosystem management, encouraging public authorities to systematically account climate

risks and long-term environmental pressures in planning and investment decisions.

For example, the integration of climate risks into decisions affecting land, water and infrastructure

would not only reduce maladaptive practices, but also help ecosystem functions and services, enhance

biodiversity resilience, and limit further degradation of natural habitats. This in turn could generate

co-benefits across environmental, social and economic dimensions, including improved water

retention, soil health and natural protection against extreme weather events. Transboundary natural

resources, such as river basins, forest or coastal areas would also benefit from greater policy coherence

and coordination. With a more systematic and coherent framework applied within and across sectors,

some environmental degradation could be slowed, halted or partially reversed in the medium to long

term. However, given the inertia of ecological systems and the already advanced state of degradation

in certain areas, some degradation remains unavoidable.

6.3 Policy Option C

Option C forms the most centralised package. The cumulative effect of the measures would push

convergence, comparability and formal integration of resilience across the Union more uniformly.

Option C lies less in changing the direction of travel than in accelerating and standardising it. Its

positive impact trajectory by 2050 would likely be significant.

EU added value

The EU added value of Option C has high potential to address transboundary risks, internal‑market

implications and shared principles for the use of public funding. A stronger common framework can

reduce fragmentation in how Member States define risk owners, tolerable levels of residual risk

and climate resilience by design requirements, while improving planning, progress monitoring and

assessment and therefore comparability and enforcement across jurisdictions.

288 (McDougal et al., 2021) 289 (European Commission. DG REGIO, 2025) 290 (European Commission. Joint Research Centre., 2020c) 291 (European Environment Agency, 2025b) 292 (European Commission. DG ECFIN, 2022)

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At EU and Member State level, Option C would create strong governance architecture and prospects

for robust implementation and should result in uniform application across the Union.

Effectiveness

This option is based on a strong coordination and convergence in climate resilience and adaptation

policy. Member States would have to change their existing systems and align their future development

with a unified EU model. While this centralisation would reduce fragmentation and raise the

ambition in the long-term - especially in geographical areas where climate adaptation is currently

less developed - it also adds new responsibilities to administrative systems. In some cases, this could

limit the margin for locally appropriate approaches. Although direct evidence on harmonised EU-wide

adaptation requirements is limited, behavioural research suggests that common rules can reduce

uncertainty, clarify expectations and promote more consistent action across jurisdictions. However,

governance evidence also indicates that obligations can remain procedural unless accompanied by

sufficient administrative capacity, sectoral expertise and effective monitoring and enforcement

arrangements.293

The direct and uniform integration of climate resilience into sectoral policies and legislation would

allow for sectors to be better prepared, especially those strategically important and risk-prone (e.g.

agriculture energy, transport). However, reviewing multiple sectoral legislation simultaneously would

require adequate capacity and knowledge to already be in place across sectors, otherwise there would

also run a risk of maladaptation or simply an administratively costly process that may not deliver on

the objectives.

The option could accelerate the alignment of investment and planning decisions across the EU,

reducing maladaptation and improving climate risk management more uniformly. Uniform

operationalisation of the duty to consider climate risks would effectively mobilise investment in public

administrations and have downstream effects for private actors. If successfully implemented, these

effects could translate into substantial reductions in residual climate risks and long-term

economic and human losses compared to the baseline.

Option C could deliver relatively uniform and robust outcomes, but they would depend heavily on

sustained political commitment and administrative capacity across all Member States, as well as

Commission’s ability to monitor progress and propose and take corrective action.

293 (Clark et al., 2025; European Commission. Joint Research Centre., 2025b; Rode et al., 2024; Wehn et al., 2015)

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Cost Efficiency

Table 7: Overview of cost/benefit for Option C

EU level MS level

Main

direct

costs

• One-off development costs for criteria,

guidance, methodologies: likely > EUR 1

million

• Harmonised policy cycle support package: >

EUR 4–5 million per cycle

• Centralised progress monitoring and reporting:

~EUR 5 million

• Revision of NAP/NAS: ~ EUR 1.5 million per MS or

more

• Broader adaptation knowledge & monitoring

platforms > EUR 3 million

• High upfront operational/coordination investments for

MSs setting up multi-level structures

Main

benefits

• Legally binding integration of climate

resilience across governance levels, sectors and

private sector

• Uniform methodologies, harmonised and

consistent monitoring and reporting at EU level

• Strengthened long-term investor confidence

and reduced exposure to macro-fiscal/public

finance shocks

• Overall return on investment potentially reaching as

much as EUR 6 for every EUR 1 input.

• Long-term: sectoral climate resilience improved, for

e.g. avoidable heat stress burden plausibly reduced by

58–70% via harmonised indicators

Economically, this option is likely to involve significant upfront costs. This includes direct costs

at EU and Member States level related to central planning, progress monitoring, assessments and

compliance assurance, combined with multiple sectoral policy revisions, more detailed transboundary

and consultation requirements and stronger private and public financing obligations. It would increase

administrative and adjustment costs for public authorities and for businesses, including SMEs,

especially in the short to medium term.

Under this Option, guidelines are transformed into legally binding obligations. While this ensures deep

integration of climate resilience across EU and national policies, it requires structural changes.

Estimates of costs at EU level are based on the costs of comparable EU external contracts which,

although undertaken at times for different purposes, are considered a reasonable proxy for

estimating the likely costs of this policy Option.

At the EU level, the one-off cost of developing common criteria and methodologies for defining the

level of tolerable risk could be estimated at more than EUR 1 million.294

The direct costs at the EU level for a full climate resilience policy cycle support package, highly

harmonised, centralised and including sectoral plans, can be expected to increase in relation to

Option B. Under this assumption, it could be estimated that these direct costs could be superior to

294 EUR 300,000 for EU Taxonomy Appendix C sectoral guidance (European Commission. DG ENV, 2024); EUR 630,000

for Pan-European fire safety mapping data and addressing data gaps (European Commission. DG GROW, 2019).

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EUR 4 to 5 million per cycle This package includes EUCRA295, revision of the Union

adaptation/climate resilience plan296 and monitoring and reporting costs.

The harmonised, centralised reporting and monitoring of progress also carries additional direct upfront

costs. Under this option, additional national and subnational data would need to be processed. While

data on building such systems from scratch is limited, using the e-platform from the Governance

Regulation297 as a benchmark, the design and implementation of such platform would be around EUR

5 million, and annual maintenance costs between EUR 100,000 and 150,000.298 .

At national level, publicly available cost evidence remains limited and uneven. As Option C

requires a more ambitious revision of NAP/NAS, which includes subnational and sectoral dimensions,

Member States direct administrative costs would also scale up.

Under the assumption that more complex governance structures would mirror higher benchmarks,

based on the available information from Portugal299 and Bulgaria300, the revision and updating of

NAP/NAS could be estimated at EUR 1.5 million per national revision cycle, but depending on the

size and governance structures of each Member State, these costs could be higher.

Broader adaptation knowledge platforms and monitoring centre packages can exceed EUR 3 million

(e.g. Romania301), if these usually combine MRE with strategy support, climate services, studies and

institutional capacity-building.

Furthermore, the integration of climate resilience under this Option C would be harmonised across

sectors. Once again, depending on the Member State, this will require operationalising an integrated,

multilevel planning, monitoring and reporting structures at national and subnational levels involving

further costs.

An example of an integrated policy cycle support, capacity-building and multi-level coordination is

Greece’s LIFE-IP AdaptInGR project, which required a budget of EUR 14.19 million over a 7-year

period. It included the development of Greece’s NAS and 13 regional adaptation action plans,

capacity-building, coordination across governance levels, monitoring and evaluation and pilot actions

in some regions and municipalities. Under Option C, Member States with more advanced systems

would not require such a big upfront investment, but those who would need to set up such frameworks

from the start, would need to do it in a shorter period of time, to be able to comply with their

obligations.

Under Option C, the integration of climate resilience across sectors will be harmonised, and depending

on the Member States governance and institutional organisation, adjustments to internal structures/

administrations might be required. For example, in the Netherlands, a Delta programme was

established at national level, against high water and flooding, to ensure fresh water and robust urban

planning. In 2026, development of strategy, knowledge products, monitoring and communication

295 Based on EUR 2 million for EUCRAs (European Environment Agency, 2024) 296 EUR 600 000 for the EU Forest Strategy (European Commission. DG ENV, 2025b); EUR 1.8 million for assistance to

the EU Nature Restoration Law and the EU Biodiversity Strategy for 2030 (European Commission. DG ENV, 2025a). 297 Which is made of two systems: Reportnet managed by the EEA and ReportENER managed by DG ENER 298 (European Commission, 2024a; Trinomics, 2016) 299 Approx. EUR 1.2 million (The EEA and Norway Grants, nd) 300 Approx. EUR 1.6 million (European Commission, nd) 301 (Ministerul Mediului, Apelor și Pădurilor, 2024)

74

activities under this centralised coordination mechanism required around EUR 2 million, and

administrative and staff costs estimated at EUR 1.65 million.302

These direct costs will vary across Member States, depending on their existing policy baselines,

specific administrative and governance structures, and geographic or population size.

Option C would achieve the lowest possible residual risk in the long-term. This is balanced with

lowered cost-efficiency as bridging that gap at the margins becomes more difficult and consequently

more expensive. For competitiveness, Option C has mixed impacts. On the one hand, it could

strengthen long-term investor confidence and reduce exposure to severe climate shocks by forcing

more robust planning and investment. On the other hand, it creates regulatory requirements which may

exceed the administrative capacity of authorities and project promoters in the short term. Here the

opportunity cost of stimulating demand and in turn helping mature a market for resilience solutions is

limited by the loss of competitive innovation environment through an overly prescriptive approach.

This could constrain the EU’s competitiveness by limiting the effectiveness and efficiency of responses

to climate-related damages.

Extensive and detailed regulatory frameworks may reduce competitiveness gains by

disincentivising locally tailored solutions and slowing innovation. Given the significant variation in

regional exposure and capacity, a uniform approach that does not account for local conditions

risks misallocating capital, increasing costs, and weakening the development of adaptive

industries such as insurance, engineering, and climate risk analytics. Reduced optimisation would

see a reduction on the investment return, which may reach as much EUR 6 for every EUR 1 input.303

In this context, over-standardisation may lead to reduced asset efficiency and maladaptive

investments, ultimately affecting negatively the EU’s long-term growth potential and

undermining its competitiveness in the face of escalating climate risks.

302 (Ministerie van Financiën, 2025) 303 (European Environment Agency, 2026d)

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Sectoral examples of the use of direct measures from the intervention

Agriculture and forestry: Avoidable losses could be moderated if Option C led to more uniform

adaptation in agricultural and forestry systems. Prevention measures focused on the wildland-urban

interface may have BCRs of 2-3:1. The addition of fuel breaks in forested areas had a BCR of

12:1.304 . Local specificities, which are critical for finding the right balance between wildfire

prevention and suppression, are difficult to address appropriately within Option C.305

Health and wellbeing: Option C would likely reduce heat-related impacts because harmonised

climate and health indicators, stronger compliance requirements and more systematic integration of

climate resilience checks would support earlier and more uniform preparedness across MS. The

broad EUCRA conclusion that heat stress becomes a critical risk by 2050 would remain, but the

avoidable burden could plausibly be reduced by approximately 58-70%.306

Infrastructure and the built environment: Mandatory climate resilience checks, harmonised

climate projections and stronger uniform integration across sectors would reduce the probability that

new infrastructure and public investments continue to lock in avoidable exposure. Under Option C,

coastal flood damage could be reduced by 76-86% with a BCR if 6.2-15.6:1. River flood damage

could also be reduced by as much as 58%.307

Finance and insurance: Under Option C, the baseline macro-fiscal risk trajectory could plausibly

be reduced, because, once implemented, it would force more uniform integration of resilience across

sectors, raise the minimum level of action, and leave laggards less room to delay or underperform.

This could further reduce the transmission of climate impacts into public finances through

infrastructure, services, territorial development, productivity, insurance and wider financial

spillovers.308

Distributional effects

Social, security and environmental outcomes would benefit from stronger and uniform

obligations. As this option establishes a legal framework with a high degree of harmonisation and

coherence of climate resilience across policies at EU and Member State levels, it could help reduce

territorial blind spots, ensure earlier consideration of transboundary and cascading risks, and support

a more systematic integration of social and environmental considerations. It could furthermore

contribute to more consistent environmental protection levels across the Union, including

transboundary resources. Option C has the potential to limit negative distributional effects which may

occur under lower levels of intervention. The introduction of detailed parameters for assessing

304 (World Bank Group, 2024) 305 Depending on the local context, fire suppression can result in fuel accumulation on the ground and lead to more severe

fires in the long run. Controlled burning – fighting fire with fire, known also as ‘fore paradox’ – is sometimes a more

successful strategy. (Kreider et al., 2024) 306 Evidence from the World Bank 2010), and the shows that adaptation effectiveness depends strongly on spatial and

sectoral heterogeneity, and that uniform approaches can lead to inefficiencies and maladaptation. To capture this effect, a

10–25% range penalty is applied here. 307 (COACCH, 2019) 308 (United Nations Development Programme, 2025)

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tolerable levels of residual risk would incentivise more precautionary and consistent management of

natural resources. In the long term, these could enable coherent restoration and conservation efforts.

However, this option’s benefits only materialise if the significant asymmetries in the relative burden

between Member States are addressed. For example, while large economies such as Germany and

France carry the highest absolute totals, smaller Member States such as Estonia and Latvia face

investment needs exceeding 1.6% of GDP, compared to an EU average of 0.6%.309 This raises

questions of fairness and solidarity. Without prescriptive measures to address these disparities, some

countries risk underinvesting in resilience, increasing vulnerability and potential reliance on assistance.

A highly standardised approach must be balanced against reduced flexibility for local

arrangements. This may limit effectiveness in some contexts, as resilience measures need to reflect

diverse regional and sectoral conditions. This could weaken local ownership and implementation in

certain areas. Work has shown that uniform approaches to funding climate adaptation in urban areas

tends to concentrate funding into specific early adopters while leaving little room for local variation

in climate adaptation measures.The highly prescriptive approach310 could stifle innovative solutions

to climate change and work against the development of tailored financial products which will be

required to finance more widespread climate adaptation. In sum, Option C could slow, stop and even

reverse environmental degradation and impacts in the long-term, if the challenges in implementation

are addressed.

7 HOW DO THE OPTIONS COMPARE?

This chapter compares the three policy options by evaluating their core measures.311 This analysis

focuses primarily on the short to medium term horizon (until 2050). However, given the topic, long-

term considerations are also included for a more comprehensive comparison. All measures across the

three policy options respond to the four SO of the initiative. However, their expected outcomes vary

in terms of EU added value, effectiveness, cost-efficiency and distributional effects. Table 8 and Table

9 summarise this comparison.

EU added value

All three options generate EU added value, but to different degrees and through different mechanisms.

Option A primarily adds value by improving the enabling framework for climate resilience, including

guidance, shared tools and enhanced knowledge exchange. However, its Union-wide impact remains

uneven, due to voluntary uptake, which lowers the level of implementation overall and preserves the

fragmentation of preparedness for climate impacts. Options B and C strengthen the EU added value

with the use of binding requirements. Option B establishes a common framework with binding

minimum requirements while preserving flexibility for national and local specificities. A highly

harmonised and centralised approach of Option C maximises convergence, comparability and

enforcement, and is particularly effective in addressing transboundary and systemic risks, however it

may raise subsidiarity concerns.

309 (European Commission. DG CLIMA et al., 2026) 310 (Venner, García-Lamarca et al., 2025) 311 A detailed table with all measures per policy option can be found in Annex 13

77

Effectiveness

Option A is somewhat effective in the short term, as it can be implemented quickly but is limited in

addressing the fragmented climate resilience in the EU and Member States. This is consistent with

evidence that soft, behaviourally oriented measures based on “best effort” alone are insufficient to

drive sustained action, and they should complement rather than substitute regulatory tools.312 Even in

scenarios where the risks are well known and understood, it is likely that with an “opt-in” scheme

presented by Option A, some Member States and policies would continue with higher level of climate

risk. It is consistent with the European Court of Auditors’ findings after the 2018 wildfire in Greece,

which carried a high death toll, that though a response capacity had been built and the risk well

understood, not enough preventative action had been taken.313

In the long term, Option C has the potential to deliver the highest long-term effectiveness through

uniform and comprehensive integration of climate resilience across sectors and Member States.

However, as this option implies the biggest changes of public and private structures, including a fast

increase in administrative know-how and capacity, and reduced flexibility to incorporate local

conditions, its effectiveness in the short to medium term is lower than for Option B. Highly prescriptive

regulation can also lead to a “one-size fits all” approach, compromised intervention and even

maladaptation. A uniform approach to regulation risks promoting simplified measures, which neglect

local conditions and become detrimental to both adaptation and cross-sectoral interaction.

By addressing key elements of SO 1 and 2, while allowing a flexible approach on the implementation

across sectors and governance levels, and triggering an effect on the private sector and population,

Option B leads to more systematic, anticipatory and coherent decision-making in the short to medium

term, while also allowing for greater levels of tailoring at a local level, and generating increasing

effectiveness gains over time.

Cost Efficiency and Competitiveness

The options differ markedly in their cost-efficiency when both short-term costs and long-term, direct

and indirect benefits are considered. In the short-term, Option A is the least costly in direct budgetary

terms, with limited EU and Member States expenditure required and low administrative burden. Both

Options B and C involve upfront administrative, compliance and investment design costs, with Option

C scoring higher due extensive harmonisation, regulatory changes and compliance requirements across

sectors and governance levels.

When looking at the medium to long-term benefits, Option A is constrained by limited and uneven

uptake, meaning that a large share of potential benefits from avoided climate damages and improved

investments do not take place. While Option C can deliver substantial long-term benefits and lower

residual risks, its cost-efficiency in the medium term is lower than Option B, due to higher

administrative burden. Due to the slower implementation, the regulatory uncertainty of Option C might

lower its effectiveness in the short to medium-term. Even if Option B has moderate direct short-term

administrative and compliance costs due to adjustments to governance systems, planning, progress

monitoring and assessment and integrating climate resilience by design in public expenditure, these

312 (European Commission. Joint Research Centre., 2025b; OECD, 2017) 313 (European Court of Auditors, 2021)

78

are outweighed over time by significant benefits, including avoided damages, economic potential (job

creation, productivity etc.), reduced maladaptation and more efficient allocation of resources.

By providing a foundation for greater protection and more harmonised resilience actions, the

framework is likely to indirectly underpin opportunities for European investors and industry to develop

and deploy novel climate resilience technologies in Europe and beyond. Option B is the best placed of

the three policy options to maximise this benefit and take advantage of this multibillion-euro market314,

with positive impacts on European competitiveness and creating an opportunity for the EU to be a

world leader in resilience technologies.

The degree to which the initiative will impact competitiveness of the Union varies across the policy

options. Option A's voluntary approach improves information but cannot create the stable, uniform

policy environment that investors need to commit capital to climate resilience solutions at scale.

Growth in the climate resilience solutions market under Option A would be fragmented; concentrated

in the most capable regions and firms, leaving the broader market underdeveloped.

Option C is the only Option which addresses it directly, but risks the opposite problem in which over-

prescription reduces the space for locally tailored innovation, may misallocate capital through uniform

treatment of structurally different contexts, and could constrain the development of adaptive industries

such insurance, engineering and climate risk analytics that thrive on differentiated local knowledge.

The over-standardisation may lead to reduced asset efficiency and maladaptive investments, ultimately

dampening long-term growth potential.

Option B is designed to navigate around both of these pitfalls. Its binding minimum requirements to

public authorities provide the regulatory certainty that unlocks private investment while its flexibility

preserves the space for differentiated locally appropriate solutions that are the source of European

comparative advantage in many resilience sectors. The indirect result is a framework that:

• Creates uniform demand across the single market without crowding out innovation;

• Provides stable policy signals to long-term investors in resilience infrastructure and

technology;

• Reduces maladaptation risk, improving the quality and efficiency of public and private

capital allocation by respecting the subsidiarity principle and local circumstances;

• Positions EU firms as first movers in global resilience markets, with a tested domestic base

to expand and export from.

Distributional effects

Under Option A, impacts are likely to remain uneven, as stronger Member States and actors are better

positioned to act on improved information and guidance, while lower-capacity regions, municipalities,

SMEs and vulnerable populations may lag behind. Even when awareness of current and future climate

risks is improved through enabling measures, such as awareness campaigns or improvement of existing

climate resilience tools, socioeconomic disparities are maintained and can widen in the long-term. It

is likely that the benefits of an initiative which relies on information and guidance will apply to those

with the highest climate literacy rather than those most in need, in turn leading to a widened resilience

314 (McKinsey, 2025b)

79

gap between societies and population cohorts.315 Consequently, the lost potential of this distributional

gap would lower the overall impact of the increased measures across the EU.

Both Options B and C improve distributional effects by embedding risk ownership, a reference

warming trajectory, improved planning, progress monitoring and assessment and just resilience into

legal frameworks. The clearer allocation of responsibilities and more systematic integration of climate

risks enable better identification of protection gaps and support more targeted measures for vulnerable

groups and regions. While differences in implementation capacity may persist, overall disparities are

expected to narrow over time making both of these an improvement over Option A.

Table 8: Comparison of the policy options

Measures SO addressed Option A Option B Option C

EU Added value

All measures combined SO1, SO2, SO3, SO4

+ ++ +++

Effectiveness

Short/med Long Short/med Long Short/med Long

Climate resilience objectives, trajectory,

duty to consider & risk ownership SO1, SO2 + + ++ ++ to +++ ++ +++

Climate risk management in sector policies, climate resilience by design

SO1, SO2, SO3

+ + ++ ++ to +++ + +++

CRAs; planning & implementation; progress and monitoring

SO1, SO2 + + ++ ++ to +++ + +++

Horizontal enablers SO2, SO3,

SO4 ++ ++ ++ ++ +++ +++

Cost-efficiency & competitiveness

Climate resilience objectives, trajectory, duty to consider & risk ownership

SO1, SO2 + + ++ ++ - to ++ + to +++

Climate risk management in sector policies, climate resilience by design

SO1, SO2, SO3

+ + ++ ++ - to + +

CRAs; planning & implementation;

progress and monitoring SO1, SO2 + + ++ ++ + ++ to +++

Horizontal enablers SO2, SO3, SO4

+ + ++ ++ ++ to +++ ++ to +++

Distributional effects

Climate resilience objectives, trajectory, duty to consider & risk ownership

SO1, SO2 - (+) + (+ to ++) + ++

Climate risk management in sector

policies, climate resilience by design

SO1, SO2,

SO3 - (+) + (+ to ++) (+ to ++) (++)

CRAs; planning & implementation;

progress and monitoring SO1, SO2 - (+) + (+ to ++) + ++

Horizontal enablers SO2, SO3, SO4

- to + (+) + (+ to ++) + (+ to ++)

Summary comparison of options + + ++ ++ to +++ + to ++ +++

Option C offers the strongest potential for uniform and equitable adaptation outcomes across the Union

in the public and private sectors, as binding and standardised requirements reduce territorial gaps and

ensure better long-term environmental safeguards, however it risks limiting local innovation in climate

315 For example EU initiatives aimed at providing information and guidance on retail financial instruments: (European

Commission, 2023c)

80

adaptation actions in some instances. Overly prescriptive policy which introduces uniform treatment

risks widening the gap between Member States by failing to consider individual contexts,

misallocating resources and negatively impacting climate resilience capacity building. Past examples

show that overprescription in other policies areas has previously led to economic divergence within

the EU and required subsequent policy reform.316

Option B facilitates concrete support through information, guidance and specified indicators (which

must be adhered to) while also allowing for local initiatives to address climate resilience gaps. As a

result, it has the most positive distributional impact, narrowing the gap between Member States,

societies and population groups.

Cross-sectoral impacts

Overall, Option A is easiest to adopt, but it is the least transformative. While Option C strongly

addresses all SO and would provide significant positive direct impacts, its rigidity and the significant

administrative capacity needed for timely implementation makes this unlikely to be practicable. Option

B, although more modest in addressing SO 3 and 4, would ensure that SO 1 and 2 prompting action

by public authorities operationalised more quickly in the short to medium term with downstream

impacts on the private sector and population.

Option B consistently fares best when compared across a range of expected sectoral impacts.

While research on the cost-effectiveness of climate resilience and adaptation measures is inherently

imprecise, context specific, and under-researched, Annex 13 (Table 5) shows some examples of

available evidence in sectors such as health, agriculture, forestry and flooding to provide indication of

the scale. These estimates are given as ranges and averages because they depend on policy details, how

things are put into practice, local conditions, and differences between policy sectors. The initiative

does not prescribe such sectoral decisions. There are specific local, national and EU processes in place

to determine appropriate policy actions and investment decisions.

For example: on wildfires317, the Commission has put forward a Communication on integrated wildfire

risk management318 and the Council has adopted recommendations that represent current political

distribution of responsibilities and potential actions at EU and national level, indicating that decisions

on management approaches are defined at national level. The Framework cannot know such choices,

and therefore will not assume specific, sectoral policy decisions to be applied across the Union. Instead,

it assumes that if the decisions are based on appropriate understanding of climate risks when weighing

costs and benefits of the risk management options, they are likely to lead to more resilient choices

before events.

With these caveats in mind, the evidence supports the conclusion that across the three policy options,

Option B appears to be the best formulated to address both current and future climate risks and make

the EU and its Member States more climate resilient.

316 For example: uniform industrial emissions reductions burdens were noted to disproportionately impact certain member

states and certain regions (COM(2019) 640 final) 317 See also for policy mix https://civil-protection-knowledge-network.europa.eu/eu-overview-risks/natural-disaster-

risks/forest-fires-wildfires 318 (European Commission. DG ECHO, 2026a)

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Table 9: Comparison of the policy options – more detailed overview with examples

*Examples of key sectoral/ thematic impacts in the table below are based on Table 5 from Annex 13

Option A Option B Option C

Very Low Moderate High

• EU: One-off studies < EUR 0.5M ; Navigator & Viewer EUR

80k/yr total ; support ~€10m/yr .

• EU: criteria < EUR 1M; EUR 4–5M/cycle support; EUR

2B/yr public funding; Navigator & Viewer EUR 80k/yr total ;

support ~€10m/yr .

• EU: criteria > EUR 1M; > EUR 4–5M/cycle support;

• MS: < €10M for voluntary update NAS/NAP and CRA; no

new mandatory compliance costs.

• MS: EUR 2–4M per MS for national policy package (incl.

CRA, NAS/NAP, Monitoring)

• MS: revision of NAP/NAS > EUR 1.5M; boader adaptation

knowledge and platforms > EUR 3M

~ 1-3 years ~ 3-6 years More than 6 years

Quickly implemented but limited in long-term scope. Operationalised quickly enough for immediate impact. Slower implementation creates near-term regulatory

uncertainty.

Short-to-Medium

Effectiveness (Until 2050)

Relies on voluntary "opt-in," leaving many areas at high risk. Drives systematic, anticipatory, and coherent action across

sectors.

Hampered by heavy structural shifts and capacity lag.

Long-Term Effectiveness

(Post-2050)

Soft, "best effort" measures fail to drive sustained action. Generates increasing gains as tailored local actions scale

over time.

Uniform integration offers maximised theoretical protection.

Distributional Fairness Favors highly capable regions; vulnerable areas lag behind. Balances minimum mandates with space for local needs. Reduces territorial gaps but risks uniform misallocation.

Fragmented & Modest Optimised & High-Value High Protection at High Cost

• Health & wellbeing: Early warning BCR of 131 but lack of

unified approach lead to heterogeneous outcomes .

• Health: Heat-related mortality by 2050 could be reduced by

77% compared to a baseline trajectory

• Health: Greening of 35% of EU's urban area - net benefits

EUR 364 bn through reduced cost of cooling

• Floods: Information can limit damage by up to 25% . • Floods: 83% of flood damages avoidable with certain

adaptation measures; BCR of 8.3–14.9 at EU mean

• Floods: ~95% coastal flood impacts avoidable via

harmonised methodology .

• Wildfires: Support tools yield BCRs of 6–39; limited

systemic/EU action so far.

• Wildfires: Wildland-urban interface measures may have

BCR 2-3, and with fuel breaks BCR of 12 .

• Wildfires: Compromised by failure to address critical local

specificities .

• Agriculture: Better uptake of climate information can lead

to modest improvements in drought preparedness in willing

regions.

• Agriculture: N/A • Agriculture: 8% water savings annually at EU level, based

on best national application efficiency.

Upfront Savings vs. Unmitigated Losses: Saves

administrative budget today, but leaves a massive share of

avoidable climate damage to occur under the baseline

trajectory.

Investment vs. Flexibility: Costs moderate capital upfront to

gain regulatory certainty, unlocking private markets while

preserving space for local implementation

Centralised Control vs. Rigid Inflexibility: high upfront

costs with later entry into force, short-medium economic

losses not avoided; and suppresses local innovation/

implementation.

Outputs/Outcomes: MSs fragmented approaches continue

as establishing trajectory/ assigning climate risk ownership is

voluntary; improvement of availability of tools but usage

varies; awareness and capacity gap widens across the EU

Outputs/Outcomes: trajectory and climate risk ownership

embeded, and harmonised methodologies/reporting reduces

duplications and fragmentation across MSs and incentivises

single market for climate resilience; improvement of

awareness of risks and solutions, which also triggers action

for private sector and population

Outputs/outcomes: maximisation of EU-wide convergence

but creates a rigid "one-size-fits-all" approach that causes

over-standardisation; harmonisation of

methodologies/reporting guarantees comparability but

generates severe admin burdens; awareness increases for

public, private sectors and population

Core Trade-offs

Direct Admin costs

Time until Full Operation

Examples of key

sectoral/thematic impacts*

82

8 PREFERRED OPTION

Overall preference for policy option B

Based on the analysis in chapters 6 and 7, Option B ‘Setting new, essential ground rules, flexible

delegation and enablers to trigger transformative change’ is identified as the preferred option.

It is expected to be the most effective for reaching the GO - making EU and Member State economies

and societies more climate resilient – producing overall better impacts across all time horizons, and at

the same time for improving the achievement of the SO.

This option is most likely to generate the urgent transformational action needed for tackling the

projected short to medium term climate impacts, and for enhancing the Union’s capacity for preparing

and coping with the expected longer-term warming levels and their consequences. By bridging these

immediate needs with future adaptive capacities, Option B mirrors the progression of short-, medium-

and long-term outcomes defined within the underlying Theory of Change and using the behavioural

change evidence to support assumptions.

The EU-wide use of a common reference warming trajectory, the clearer attribution of climate

risk ownership (each supported by 70% of the OPC respondents), the creation of a general duty to

consider climate risks, and the requirement to prepare regular and harmonised climate risk