Reynand Wu
As the global community grapples with the accelerating impacts of climate change, a significant administrative and political bottleneck has emerged within the United Nations’ climate framework. More than a year past the February 2025 deadline, at least 50 countries have yet to submit their updated Nationally Determined Contributions (NDCs)—the cornerstone of the Paris Agreement’s ambition to limit global warming.
The failure to submit these plans is not merely a bureaucratic delay; it represents a stalling of the collective engine designed to curb planet-heating emissions. While the Paris Agreement relies on a "bottom-up" approach, where nations voluntarily commit to increasingly ambitious targets, the absence of these documents leaves a concerning void in the global effort to align national policies with the scientific necessity of limiting temperature rises.
The State of Play: A Breakdown of Missing Plans
The Paris Agreement’s Implementation and Compliance Committee (PAICC), the body tasked with overseeing adherence to the accord, confirmed in a March meeting that 55 countries had failed to communicate their updated NDCs. While the UN registry shows that two nations have trickled in with submissions since that assessment, the core group of non-compliant states remains stubbornly large.
The missing submissions are largely concentrated among smaller or developing nations. However, the list is not exclusively composed of minor emitters. Among those yet to finalize their plans are significant economies, including Egypt, Vietnam, Argentina, and the Philippines.
The United States and Iran remain outside the scope of these specific obligations. The U.S., which submitted a 2035 NDC under the Biden administration, saw that progress effectively erased when the subsequent Trump administration withdrew the nation from the accord. Consequently, the absence of the world’s second-largest emitter creates a massive gap in the global ledger, though the PAICC’s current focus remains on the sovereign states that have officially ratified the treaty but are failing to fulfill their reporting duties.
Chronology of Compliance and Delay
The timeline for the current round of NDCs was established to ensure that by 2025, the world would have a clear roadmap for 2035. The process is designed to be iterative: every five years, nations are expected to ratchet up their climate ambition, moving from initial pledges to more rigorous, policy-backed commitments.
- February 2025: The initial deadline for the third round of NDCs, focused on 2035 targets.
- April 2025: A massive backlog existed, with 171 governments having failed to submit their plans.
- March 2026: The PAICC meets to review progress. Despite months of reminders, 55 countries remain in default.
- March 27, 2026: The PAICC releases a report expressing "noted concern" regarding the lack of transparency and communication from a subset of these nations.
- Future Outlook: The committee is scheduled to reconvene in September 2026, where the possibility of "naming and shaming" non-compliant nations will once again be on the table.
The "Silent" Nations: Lack of Communication
Perhaps more concerning than the missing NDCs themselves is the silence from nearly half of the non-compliant group. According to the PAICC’s March report, 28 countries have not only failed to provide their NDC, but have also neglected to communicate their biennial transparency reports—the documents that track actual progress on the ground.
This silence has persisted despite multiple formal reminders from the UN. The PAICC board, in an attempt to bridge this communication gap, has opted to send individual letters to these governments. These letters serve as a formal "nudge," reminding them that the committee possesses the mandate to facilitate implementation and promote compliance, though the specific mechanisms for doing so remain deliberately soft.
Understanding the Obstacles: Conflict and Capacity
Not all instances of non-compliance stem from political obstructionism. Many of the nations in question cite "exceptional circumstances" that render the resource-intensive task of climate modeling and policy consultation nearly impossible.
Sudan serves as a poignant example. A letter from a Sudanese official to the PAICC, obtained by Climate Home News, explicitly states that the country’s ongoing civil war has led to the complete suspension of NDC preparation. When a nation is fighting for survival, the long-term planning required for a decade-spanning climate strategy often becomes a secondary priority to immediate humanitarian relief and stability.
However, the "mixed crowd" of missing submissions includes nations that do not face such existential crises. Sources close to the PAICC process indicate that the list of silent nations includes least-developed countries, small island states, and even some emerging economies that possess the technical capacity to report but have failed to prioritize the process.
Implications of a Non-Punitive Regime
The architecture of the Paris Agreement was intentionally crafted to be "non-adversarial and non-punitive." This approach was a direct reaction to the failure of the 1997 Kyoto Protocol. Under the Kyoto regime, nations faced stringent enforcement mechanisms and potential financial penalties for missing targets. When it became evident that Canada would fail to meet its obligations in 2011, it opted to withdraw from the agreement entirely rather than face formal non-compliance proceedings.
Tejas Rao, a doctoral researcher at the University of Cambridge, argues that the current system’s lack of "teeth" is a feature, not a bug. By prioritizing engagement over coercion, the UN hopes to keep all parties at the table.
"Enforcement proceedings became politically toxic," says Rao. The lesson learned from Kyoto was that if you push a country too hard, they will leave the club, which is the worst possible outcome for a global climate accord. The current system relies on the assumption that governments will comply when they feel they have agency, rather than feeling forced into submission.
The Limits of "Naming and Shaming"
Despite the desire for a non-adversarial process, there is a growing consensus that the "naming and shaming" strategy—the most powerful tool the PAICC currently holds—is being underutilized.
Joanna Depledge, a historian of the UN climate process at the University of Cambridge, notes that while any stronger measures (such as sanctions) would have been rejected by negotiators in 2015, the current reluctance to even name countries that ignore reminders is problematic. "Naming and shaming in the international arena is not trivial," Depledge explains. "Governments do not like to be exposed as non-compliant. But if the PAICC cannot even name the culprits, then that is a serious problem."
The PAICC has yet to issue a formal public finding naming a government for a breach of rules. In 2023, the committee took a very soft approach, noting that the Vatican had not filed an NDC and that Iceland had not provided information on climate finance. By keeping the language focused on "noting with concern" rather than "issuing a formal finding of non-compliance," the committee risks appearing toothless to the public and to the very governments it seeks to influence.
Conclusion: A Delicate Balance
The progress in the last year is undeniable. The reduction of the non-compliant list from 171 in April 2025 to roughly 50 today suggests that the committee’s "nudge" strategy is working, albeit at a glacial pace.
The fundamental tension of the Paris Agreement remains: How do you enforce a global treaty when the signatories are sovereign states that can leave at any time? The PAICC is currently navigating this thin line, trying to facilitate compliance without triggering the political backlash that destroyed its predecessor.
As the September meeting approaches, the committee faces a crucial test. Will it continue to favor the "soft touch," hoping that quiet diplomacy will eventually yield results, or will it embrace a more transparent, albeit confrontational, approach to accountability? For the millions of people living on the frontlines of climate change, the answer to that question could determine whether the Paris Agreement remains a viable blueprint for survival or a collection of broken promises.
Rifan Muazin
Layla Zulfa
