Publication

Final NECPs, Energy Poverty & Energy Efficiency Targets: Where do we stand?

Apr 2025

Topics:

Energy poverty
Energy savings obligation, monitoring and verification

Project:

Where Do We Stand on Tackling Energy Poverty in NECPs?

As part of their energy savings obligation and according to Article 8(3) of the Directive 1791/2023 (EED), Member States shall implement energy efficiency obligation schemes, alternative policy measures, or a combination of both, or programmes or measures financed under a national energy efficiency fund, as a priority among, but not limited to, people affected by energy poverty, vulnerable customers, people in low-income households and, where applicable, people living in social housing. Furthermore, Member States shall establish and achieve a share of the required amount of cumulative end-use energy savings required by Article 8(1) among these priority groups.   

While the EED provides a definition for energy poverty, the concept of vulnerable customers is less clearly defined and can be determined pursuant to Article 3(3) of Directive 2009/73/EC on gas market and Article 28(1) of Directive (EU) 2019/944 on electricity market2 taking into consideration the final users.  

Finally, vulnerable households, microenterprises and transport users are acknowledged within the context of the Social Climate Fund by Regulation (EU) 2023/955, as they can be significantly affected by increases in energy prices, notably due to the extension of the Emission Trading Scheme to fossil fuels used in buildings and road transport. These groups are not limited to households experiencing energy poverty. They can for example include lower-middle income households, who would struggle to renovate their homes, replace their vehicle or shift to other transport modes.   

Notably, the various EU regulations (on electricity and gas markets, and on SCF) take varying approaches to vulnerability, reflecting distinct priorities, such as energy affordability, income levels, or exposure to greenhouse gas pricing, as in the case of the SCF Regulation.   

As measures and policies foreseen in the Social Climate Plan will also contribute to the achievement of Member States’s Article 8 targets (especially the sub-target for Article 8(3)), it is crucial to provide clarity and define appropriately the concepts of energy poverty and vulnerability. These definitions must align with the SCF’s intention to target vulnerable households.

Go through the ENSMOV Plus brief exploring the latest NECP updates regarding Energy Poverty in Member States.

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