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Insight

What NDCs 3.0 Are (and Aren’t) Saying About Fossil Fuel Production: COP 30 update

After the International Court of Justice (ICJ) published an advisory opinion in July reinforcing states’ legal obligations to stop fossil fuel expansion, including by providing fossil fuel subsidies, the imperative for ambitious nationally determined contributions (NDCs) has never been clearer. Yet most of the 89 third-generation NDCs submitted to date still fall short of confronting the root causes of the issue, such as government support for production and licensing of new fields. In this article, we look at the dominant, emerging, and innovative approaches to addressing fossil fuel production in countries’ climate plans and their implications for the 30th UN Climate Change Conference (COP 30) and beyond.  

By Paola Andrea Yanguas Parra, Natalie Jones, Ruth Bandomah Baba on November 17, 2025

The run-up to COP 30 has been defined by growing clarity about the role of fossil fuel production in the climate crisis. The ICJ advisory opinion, issued in July 2025, confirmed that states have a legal obligation to take all necessary measures to prevent harm from climate change, including addressing the sources of emissions, including fossil fuel production and fossil fuel subsidies. The ICJ advisory opinion also confirmed that in the context of the Paris Agreement, NDCs must be progressively more demanding over time, reflect the highest possible ambition, and be informed by the global stocktake (GST).

The science is clear that there is no room for new oil and gas fields, or new coal mines, in a 1.5°C world. Ending the issuance of new exploration licences is a critical step toward ending new fields altogether. At the same time, the United Nations (UN) Emissions Gap Report, the Production Gap Report, and the UNFCCC NDC Synthesis Report all highlight a widening gap between global climate targets and national action, particularly in relation to fossil fuels.

At COP 28, parties to the Paris Agreement agreed, in the GST outcome, to “transition[] away from fossil fuels in energy systems, in a just, orderly and equitable manner.” Since then, many global leaders have urged countries to address this core issue in their new climate plans, including the UN Secretary General and the Brazilian President Lula da Silva, who opened COP 30 by stating that the world must move away from fossil fuels.

With 89 NDCs 3.0, representing 115 countries, submitted as of November 17,1 the picture is clearer than when IISD wrote about this topic earlier this year. NDCs increasingly refer to fossil fuel production, just transition, and international cooperation, signaling progress and a response by most countries to the GST call. Yet the majority of producing countries still avoid committing to actual reductions in production, focusing instead on reducing emissions from extraction and transportation processes.

The Dominant Topic: Reducing emissions from production

On the one hand, 31 out of the 402 fossil fuel-producing countries that have submitted their NDC 3.0 mention fossil fuel production: a clear majority. Notable omissions are China, Türkiye, and Norway, which, despite being among the largest 20 fossil fuel producers in the world, do not mention production explicitly in their NDC. In addition, five countries that do not produce fossil fuels mention fossil fuel production: the Marshall Islands, Moldova, Vanuatu, Kenya (which has large untapped oil and coal reserves), and Uruguay (which has oil and gas exploration). Addressing the central cause of climate change in their NDCs is a good start.

On the other hand, the majority of fossil fuel-producing countries focus on measures for mitigating emissions from production (22 out of 40), or international cooperation measures (13 out of 40), rather than on measures to wind down production.

While reducing production emissions is an important first step, it does nothing to address Scope 3 emissions (resulting from the downstream fossil fuel combustion), which are by far the largest component of fossil fuel emissions.

 

Moreover, it is concerning that some producing countries, including Brunei, Nigeria, and Uzbekistan, include references to their intention to increase fossil fuel production, while others, including the United Arab Emirates and Azerbaijan, base their fossil fuel production emission reduction strategy on technologies that are not available at scale, such as carbon capture, utilization, and storage technology.

“Transitioning Away”: No new licences, no new public financing

A true “transitioning away” approach would be to set quantitative targets for reducing fossil fuel production altogether. No country includes such targets in their NDC. However, some countries are taking steps along the way. Concrete measures to disincentivize or wind down fossil fuel production have been addressed by Australia, Colombia, and the United Kingdom. These are some constructive examples from NDCs submitted so far with measures to disincentivize or wind down fossil fuel production, which countries that are still to submit their NDCs can emulate:

  • The United Kingdom’s NDC states that it will undertake consultation on halting new oil and gas licences to explore new fields.  
  • Colombia’s declarative NDC refers to its decision to suspend new hydrocarbon exploration contracts, while advancing in the planning of a progressive reduction in the use of fossil fuels.

Similarly, ending national and international public finance for fossil fuels is essential to transitioning away from them. Therefore, NDCs should provide a pathway for ending public financial support for fossil fuels, including production. Only two countries make explicit references to ending fossil fuel production support:  

  • In its new NDC, Australia includes several measures it has taken to restrict direct support for the fossil fuel energy sector, including prohibiting direct financing for the extraction of coal and natural gas and restrictions for infrastructure construction support when the primary purpose of extracting coal, crude oil, or natural gas.
  • Canada’s NDC includes a reference to its ending of new direct public support for the international unabated fossil fuel energy sector.

Canada and Australia, together with 38 other countries, are members of the Clean Energy Transition Partnership, signatories of which have reduced their fossil fuel international public finance by up to 78% in 2024 compared with before the partnership was signed.

Subsidies and other forms of public support to fossil fuels represent the opposite of “transitioning away,” and reform of public finance for fossil fuels could liberate substantial fiscal space to finance a just transition away from fossil fuels. However, it is a topic that also receives very little attention in NDCs, with only 103 of the NDCs 3.0 mentioning fossil fuel subsidy reform.

A car sits at a gas station
A car sits at a gas station. Reforming fossil fuel subsidies is essential to transition away from fossil fuels.

Economic Diversification and Just Transition

Subnational (and sometimes national) economies of fossil fuel-producing regions (or countries) are usually highly dependent on the fossil fuel sector for fiscal revenue generation, exports, and jobs. Therefore, a just, orderly, and equitable transition away from fossil fuels in those countries and their regions concentrating most of the fossil fuel activity should address economic diversification and just transition issues.  

Accordingly, mentions of just transition and economic diversification highlighted in the third generation of NDCs have increased considerably in comparison to previous NDCs update rounds, with 13 countries out of 40 producing countries referring to concrete just transition measures, and 11 out of 40 referring to economic diversification measures.

On the just transition side, some examples to highlight include:

  • Azerbaijan mentions its collaboration with the International Labour Organization to create social protection frameworks to support workers during the transition to a green economy, with measures like unemployment benefits, retraining programs, and job placement services for those affected by the decline of fossil fuel-based industries.
  • The European Union includes references to its Just Transition Fund, which mobilizes EUR 19.2 billion of EU investments to help the people and places that suffer the most from the transition to climate neutrality.
  • Nigeria mentions its Just Transition Guideline Programme, targeted at retraining the workforce, financial support to green entrepreneurs, among others, targeted at those impacted by decarbonization, such as the oil and gas workers.
  • Iraq indicates that it will distribute funds proceeding from Article 6 (carbon markets) to community development, retraining of workers, among others, to ensure fairness and achieve equitable outcomes across all regions, including oil-producing provinces.

On the economic diversification side, some examples to highlight include:

  • Brunei Darussalam’s NDC makes references to its Vision 2035 Strategy, which focuses on diversifying the economy and fostering investments in non-oil sectors such as food, tourism, information and communications technology, and services.
  • The United Arab Emirates’ NDC notes the success of its economic diversification strategy, which has resulted in the non-oil sector’s share of GDP increasing from 30%–40% in the 1970s to around 75% today.  
  • Venezuela has not submitted an NDC 3.0, but in its new NDC 2.0, it mentions its efforts to diversify the economy and move beyond oil dependency, within strategic development frameworks for 13 strategic sectors.

International Cooperation and Equity

Perhaps the most interesting examples of discussion topics that we observed in the new round of NDCs related to fossil fuel production are the references to international cooperation. They are particularly interesting, since not only producing countries but also some fossil fuel importers have started to refer to this topic, as a response to the GST call to address the issue.  

First of all, many countries make explicit references to equity considerations around the topic of fossil fuel production:

  • Kenya’s NDC states that to forego “the benefits of exploiting" its fossil fuel resources, “significant compensatory international support will be required.”  
  • Bolivia includes a warning of the dangers of an unmanaged transition, declaring itself as a “victim of an unfair energy transition, as by drastically reducing fossil fuel production, it went from being an exporter to an importer, allocating more resources to paying off its foreign debt.”
  • Nigeria points to its dilemma to “balance its economy, which is fossil fuel-based, with vital climate action, alongside needed socio-economic development” pointing to its low and slow-evolving Human Development Indicators.  

Also, increasingly, both producer and importer countries make references to international alliances that address the issue of fossil fuel production:

Finally, many countries make clear calls in their NDCs for the international community, in particular fossil fuel producers, to finally address the issue of fossil fuel production in the context of climate change mitigation. For instance, non-producing countries, like the Marshall Islands, call on fossil fuel producers “to act with the same ambition” and “collectively plan a just, fair, and orderly transition away from fossil fuels.” Similarly, Vanuatu urges all states to align their NDCs to comply with the obligations and standards as clarified by the ICJ and to “address and remedy any conduct relating to anthropogenic greenhouse gas emissions that may amount to internationally wrongful acts, whether that be through extraction, production or consumption of fossil fuels.”  

Some producers also call to action on the issue. For instance, Colombia states that it is “aware of the shared responsibility to act with transparency and evidence” and it “understands that the paths of decline in the production and consumption of fossil fuels will be determined progressively, based on the best scientific information." Finally, Brazil’s NDC states that Brazil would “welcome the launching of international work for the definition of schedules for transitioning away from fossil fuels,” with “developed countries taking the lead.” 

Photo of COP30 venue in Belem
COP 30 in Belém offers an opportunity to shape the transition away from fossil fuel production. Photo by IISD/ENB | Mike Muzurakis

What does this mean for COP 30 and beyond?

As negotiations continue at COP 30, one of the clearest measures of success will be whether countries are willing to explicitly confront the role of fossil fuel production in driving the climate crisis. The science is unequivocal, the legal mandate has been sharpened by the ICJ advisory opinion, and the political expectation is now on the table: transitioning away from fossil fuels requires more than improving efficiency or reducing methane leaks. It requires planning for a managed and equitable reduction in production. With 89 NDCs 3.0, representing 115 countries, submitted so far, we see encouraging signs of progress in the way countries frame the transition—more references to just transition, economic diversification, and the need for international cooperation. Yet for many of these NDCs, the core question remains unanswered: how, and on what timeline, will fossil fuel production decline?

For COP 30 to mark a real turning point, countries that have not yet submitted their NDCs should do so with clear commitments on fossil fuel production, reflecting the agreed global goal of transitioning away from fossil fuels in a just, orderly, and equitable manner.

 

Meanwhile, countries whose NDCs acknowledge fossil fuels only indirectly, or solely through measures to reduce production emissions, should consider resubmitting more ambitious NDCs or, at minimum, developing implementation plans that translate long-term intentions into concrete steps. National transition plans, sectoral roadmaps, subsidy phase-out schedules, and regional just transition strategies all offer pathways to operationalize these commitments.

One outcome of COP 30 could be a high-level, inclusive dialogue on a just, orderly, and equitable transition away from fossil fuels, with developed countries leading in line with common but differentiated responsibilities and respective capabilities. Building on Brazil's NDC proposal to define "schedules" for the transition, such a dialogue could address the NDC implementation gap on energy outcomes, linking mitigation ambition with finance, justice, and equity, as well as highlight the socio-economic risks of a disorderly transition.  

A less sustainable alternative would be that this discussion could take place as one topic within a bigger dedicated space in the negotiations to address the large ambition and implementation gap of NDCs. This would be in line with the Alliance of Small Island States' proposal on an NDC “dedicated space” that examines barriers to the implementation of conditional elements of NDCs with a view to resolving systemic barriers to increase mitigation action. According to this proposal, this space could be in the form of a roadmap/technical dialogue/contact group/work program/expert group and/or a standing agenda item.  

Regardless of the concrete mechanism to address this in the UNFCCC, ignoring fossil fuel production is no longer a viable option politically, economically, or scientifically. As the world looks to Belém, COP 30 offers a unique opportunity to move beyond statements of intent and begin shaping the practical, fair, and coordinated transition away from fossil fuel production that the Paris Agreement ultimately requires.

  1. We have also analyzed the NDCs 2.0 of six countries that have submitted them in 20205: Botswana, Djibouti, Honduras, Lesotho, St Vincent and the Grenadines, and Venezuela. We, however, don't include those in the general counts given in this article.
  2. Angola, Australia, Azerbaijan, Bangladesh, Bolivia, Brazil, Brunei, Canada, China, Colombia, Côte d'Ivoire, Ecuador, European Union, Indonesia, Iraq, Japan, Kyrgyzstan, Malaysia, Mongolia, Morocco, Mozambique, New Zealand, Nigeria, Norway, Pakistan, Peru, Russia, Serbia, South Africa, Suriname, Thailand, Tunisia, Türkiye, Ukraine, United Arab Emirates, United Kingdom, United States, Uzbekistan, Yemen, Zimbabwe.
  3. Angola, Australia, Canada, Chile, the European Union, Malaysia, Republic of the Marshall Islands, the United Kingdom, and Uzbekistan. 

    Editor's note: Mexico’s NDC 3.0 was submitted a couple of hours after this article was published. Including Mexico, the total of NDCs submitted by 17.11.2025 would be 90, representing 116 countries. This NDC would also bring the count of fossil producers that have submitted an NDC 3.0 to 41, the count of how many have addressed fossil fuel supply issues to 32, and the count of which countries focus their measures on mitigation measures to reduce fossil fuel production emissions to 23.