Türkiye's NDC 3.0 Document On The Road To COP31: Critiques And Assessments

Turkey's Second Nationally Determined Contribution ("NDC 3.0"), submitted to the United Nations Framework Convention on Climate Change within the context of the COP30 process, is widely regarded not merely as a technical target-setting document, but as a strategic policy instrument directly linked to Turkey's broader development trajectory, energy security considerations, industrial policy priorities, and international positioning. In this respect, NDC 3.0 is assessed as providing a multi-layered framework that goes beyond climate policy alone and serves as a reference text testing coherence across different policy domains.

Within this context, the document has been examined in detail by academic circles, international assessment bodies, policy analysis centers, and civil society organizations active in the environmental field. The assessments undertaken tend to focus on the ambition level of the targets, the methodological design, the relationship between targets and implementation instruments, governance capacity, and long-term credibility. This paper aims to bring together these assessments and present critiques of NDC 3.0 within a systematic and holistic framework.

Target Structure and the Debate on Absolute Emissions Reductions

At the core of the critiques directed at NDC 3.0 lies the absence of an explicit commitment to an absolute reduction in greenhouse gas emissions. Academic and technical assessments note that the target presented for 2035 is primarily defined in comparison to a business-as-usual ("BAU") scenario; as such, when current emission levels are taken as a reference point, it is considered possible that emissions may continue to increase in the medium term. This approach is widely viewed as being misaligned with the growing emphasis, under the Paris Agreement framework, on absolute emissions reductions.

It is further indicated that the reliance on percentage-based reduction narratives complicates the assessment of the targets' actual climate impact and creates uncertainty, both domestically and internationally, regarding the real ambition level of the targets. In this regard, it is noted that NDC 3.0 has become a subject of discussion not only from a technical standpoint, but also in terms of policy communication and international credibility.

Interim Targets, Emissions Peak, and Alignment with Net Zero

Another key area of critique concerns the absence of a clearly defined emissions peak for the 2030–2035 period. It has been suggested in academic circles that the absence of an interim reduction pathway could be seen as weakening accountability.

The absence of interim targets is also seen as increasing uncertainty regarding which sectors will undergo transformation, to what extent, and within which timeframes.

This situation is widely interpreted not merely as a technical gap, but also as an indication of weak policy signalling. It is noted that, unless long-term targets are supported by short- and medium-term implementation steps, the credibility of the target declarations may be subject to question.

Approach of International Assessment Organizations

Analyses published by international assessment organizations suggest that Turkey's current NDC targets are not aligned with the Paris Agreement's 1.5°C objective. Climate Action Tracker, for instance, assesses Turkey's targets within the "insufficient" or "critically insufficient" categories. Similarly, the United Nations Environment Programme's Emissions Gap Reports emphasize that existing national contributions remain inadequate to limit global temperature increase.

These assessments suggest that Turkey's position within global climate governance is evaluated not only on the basis of its target declarations, but also in terms of the feasibility of implementation and whether these targets are supported by financing mechanisms.

Methodology, BAU Assumptions, and Policy Coherence Challenges

Policy analysis institutions and civil society organizations assessments indicate that the methodological framework of NDC 3.0 is largely based on BAU assumptions. In this context, the Turkish Economic Policy Research Foundation (TEPAV) highlights that the failure to clearly articulate the absolute emissions trajectory reduces predictability for policymakers and investors, and that the relationship between NDC targets and emissions trading systems, energy transition policies, and industrial strategies has not been sufficiently clarified. ¹

Similar assessments point out that, unless targets are supported by measurable and enforceable policy instruments, the economic and institutional foundations of long-term climate objectives may be weakened. This situation places policy coherence and implementation capacity at the center of NDC 3.0-related discussions.

Phase-out of Fossil Fuels and Energy Policies

Evaluations by İklimhaber ² and İklim Ağı ³ indicate that NDC 3.0 does not present a clear, time-bound, or binding roadmap for phasing out fossil fuels, particularly coal. When considered alongside existing energy and mining policies, this is viewed as increasing the risk of continued fossil fuel dependency.

It is further emphasized that the inconsistency between the continued provision of fossil fuel subsidies and climate targets constitutes a significant challenge to policy credibility. At the same time, it is underlined that renewable energy investments should be planned in a manner consistent with nature conservation principles and participatory local governance mechanisms.

Assessments by Civil Society Organizations

In assessments conducted by civil society organizations active in the fields of environment and climate, the absence of absolute emissions reductions, binding interim targets, and a coal phase-out timetable are identified as shared areas of critique. These organizations emphasize that climate policies should be addressed not solely from an emissions reduction perspective, but through a holistic approach that also encompasses economic predictability, nature conservation, food security, and natural disaster risk.

Civil society assessments further note that the social impacts of climate policies and the just transition dimension have not been sufficiently addressed, and that this may weaken societal acceptance of climate policies. ⁴

Overall Assessment

When assessed in a holistic manner, the critiques put forward by academic circles, international assessment bodies, and civil society organisations indicate that, in its current form Türkiye's NDC 3.0 document raises questions with regard to ambition level, methodological transparency, policy coherence, and implementability. In particular, the absence of a clearly defined emissions trajectory for the interim period, the lack of binding policy signals concerning a gradual phase-out of fossil fuels, and the limited clarity on the alignment between targets and concrete implementation instruments have emerged as key areas of concern. These elements collectively shape prevailing assessments regarding Türkiye's positioning and credibility within the international climate regime.

Within this context, Türkiye's decision to host COP31 is widely regarded as a development that significantly elevates the importance of such assessments. Beyond its diplomatic dimension, COP31 hosting is increasingly viewed as an opportunity for Türkiye to demonstrate policy coherence, institutional capacity, and long-term commitment to climate objectives. The process leading up to COP31 is therefore expected to attract heightened international attention, particularly with respect to the extent to which national targets are supported by predictable, transparent, and implementation-oriented policy measures.

Against this backdrop, COP31 may also serve as a constructive catalyst for strengthening Türkiye's climate policy architecture. The period ahead offers scope for clarifying interim emissions pathways, reinforcing implementation mechanisms, and signalling a more consistent transition away from fossil fuel dependency. If effectively leveraged, the COP31 process could contribute to enhancing confidence among international partners and investors alike, while supporting Türkiye'spositioning as a proactive, credible, and solution-oriented actor within the evolving international climate regime.

Footnotes

1 https://www.tepav.org.tr/tr/yayin/s/2130

2 https://www.iklimhaber.org/turkiyenin-yeni-iklim-hedefi-ile-emisyonlar-artmaya-devam-edecek/

3 https://iklimagi.org/hedef-varsa-hayat-var/

4 https://lemonchiffon-goldfinch-775441.hostingersite.com/iklim-agindan-2025-iklim-karnesi/

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