References to equality can be found in the majority of the plans and emerge in three main contexts: unequal exposure to climate change, economic and distributional (in)equality and gender (in)equality.

The disparate impacts of climate change and climate transition measures are considered both in the context of geographical exposure and specific groups. The Croatian NECP directly refers to the principle of equal treatment as an underlying objective which needs to be realised ‘when applying the NECP and considering the effects of its provisions’ (p. 109). The Greek NECP stipulates ‘ensuring equality, inclusion and non-discrimination’ as one of the aims in the context of fair labour transition and addressing its socioeconomic consequences (p. 188). The Lithuanian NECP refers to the principle of ‘equal opportunities for all’ expressed in the Lithuanian cross-cutting strategy until 2030 (National Progress Plan), which ‘ensures that all persons, regardless of their sex, nationality, racial or ethnic origin, nationality, language, religion, beliefs, beliefs or opinions, disability, state of health, social status, age, sexual orientation or other characteristics, have equal rights and access to services, facilities, transport and other means to participate in public life’ (pp. 130–131). It stresses the need to analyse and integrate this principle in climate governance. Other NECPs do not explicitly refer to the principle of equal treatment in the context of NECP implementation (though some mention it, such as in the context of access to energy).

Many NECPs include some consideration of socioeconomic inequalities and distributional aspects of climate transition policies. For example, the Irish NECP stresses that some regions and households are more vulnerable than others to the effects of both climate change and decarbonisation, and highlights that the cost of transition should be shared in a way that does not exacerbate existing inequalities (p. 222). It also notes the potential for climate action to enhance social equality (p. 409). The Dutch NECP also acknowledges the risk of negative distributive impacts of climate policies on social inequalities (p. 11). The Portuguese NECP states that the cross-cutting foci of the plan include ‘people first: a better demographic balance, more inclusion, less inequality’ (p. 32). The Slovenian NECP also highlights the need to ensure the fair distribution of costs and benefits of transition, and the need for ‘designing and implementing other policies that contribute to reducing levels of inequalities in society’ to ensure a just transition (p. 5).

Climate change itself, and mitigation or adaptation measures adopted to tackle it, have the potential to exacerbate existing gender inequalities. The European Institute for Gender Equality’s Gender Inequality Index analysis has shown that in the 2019 NECP draft submissions, only 10 NECPs referred to gender equality, and only did so partially and superficially. FRA’s analysis of the updated NECPs submitted in 2024 and 2025 shows that three Member States have removed all references to gender and only nine Member States refer to gender equality (see Table 2), and even these references remain mostly superficial. More detailed and nuanced research is needed. For example, the Finnish gender impact assessment covers six sectors: energy production, construction and buildings, transportation, industry, the service sector and agriculture. It stresses that increasing the inclusion of women and young people in climate policies, who are more prepared to make and support climate-friendly decisions, would contribute to higher emission reductions. The Spanish NECP highlights gender equality as a key cross-cutting factor in the climate transition and outlines that the Spanish gender equality strategy [3] The Third Strategic Plan for the Effective Equality of Women and Men 2022–2025.
‘integrate[s] ecological and social sustainability from an intersectional gender approach’ (p. 355). The Latvian and Lithuanian NECPs highlight the gender dimension of climate change impacts and gender inequality in climate governance. For example, in Lithuania, ‘in 2022, only 29 % of decision-makers in parliamentary committees focusing on the environment and climate change were women’ (p. 14).

NECPs often define vulnerable households as energy consumers who are unable to afford their energy costs, although this varies between Member States. The Luxembourgish NECP defines low-income households with high energy consumption as vulnerable. However, in some NECPs, the definition of vulnerable households is developed further. The Irish, Italian, Lithuanian and Maltese NECPs, emphasise specific groups with potential health vulnerabilities who are at greater risk of experiencing undue harm from the detriments of energy poverty. Both the Italian and the Irish NECPs make explicit reference to vulnerable households, including people with serious health conditions, who depend on the use of energy-powered medical and therapeutic equipment necessary for their survival. The Dutch and Latvian NECPs include those experiencing transport poverty as vulnerable groups. The Latvian NECP also identifies those with a low-level of education and women as vulnerable and at risk of poverty. Single parent families are categorised as vulnerable in the Lithuanian, Romanian and Swedish NECPs. In the Italian NECP, the definition of vulnerable households also includes the inhabitants of small islands and residents in emergency housing facilities.

Whether framed strictly as energy consumers or within nuanced categories as listed above, all NECPs frame priorities for vulnerable groups in the context of energy poverty, identifying communities that have inadequate access to basic energy services. As such, NECPs include strategies tackling energy poverty through affordable energy renovations, financial support and awareness raising.

While every NECP refers to equal access to energy, only seven plans mention affordable housing, despite the close link between energy poverty and housing (see Chapter 1.4). The Irish NECP highlights the ‘Housing for All’ plan, Ireland’s national housing plan aimed at delivering an average of 6 000 affordable homes per year for people of all needs. Croatia’s NECP lists ‘facilitating access to affordable housing’ as one of the measures to be financed from the Social Climate Fund. The German NECP emphasises the need to be attentive to the social aspects of the just transition, including the need to guarantee affordable housing for everyone. Similarly, in Luxembourg’s NECP, there is a recognition that rising housing prices are limiting low-income population groups to poorly maintained housing, encouraging the construction of affordable housing. The Czech NECP outlines the country’s long-term vision of a secure, affordable and sustainable supply of households and energy. Plans which do not make direct reference to affordable housing use the concept of affordable energy when outlining housing strategies that typically come in the form of renovation and energy upgrades, subsidies supporting those in financial need and building new housing stock. Housing is mainly considered within the context of decarbonisation and energy efficiency targets. Housing renovations are also a way of guaranteeing a home of an adequate standard that supports the needs of its inhabitants (see Chapter 1.4). This is reflected in several NECPs, which mention empowering and creating climate-resilient households in their housing strategies. The State Housing Plan referred to in the Spanish NECP has the goal of, among other things, facilitating the availability of decent and adequate housing for older people and people with disabilities. The French NECP refers to France Rénov’, a public service housing initiative, which was established to, inter alia, inform and empower households throughout the renovation process and to help address injustice that can potentially be caused in the decarbonisation process.