On 16 July 2025, the European Commission presented its proposal for the next Multiannual Financial Framework (MFF), which will run from 2028 to 2034. Climate and environmental themes have been heavily restructured compared to the previous (2014-2020) and current (2021-2027) MFF cycles.
Climate and environmental themes are currently represented by a variety of specific and mainstreamed funds, headings and programmes. In contrast, in the 2028-2034 MFF, climate and environment spending will be delivered primarily through:
- the National and Regional Partnership (NRP) Fund, implemented through Member State National and Regional Partnership Plans (NRPPs), with at least 43% (EUR 427.1 billion) of national allocations dedicated to climate and environmental objectives, and;
- the European Competitiveness Fund (ECF), a centrally managed instrument supporting industrial decarbonisation, clean transition and competitiveness objectives, with the same 43% budget (EUR 46.91 and 100.75 billion) climate and environment allocation requirement.
Next hereto, a single 35% horizontal spending target for climate and environment would apply across the EU budget, supported by the continued application of the ‘do no significant harm’ (DNSH) principle.
In March 2026, Trinomics prepared a study for the European Parliament’s Committee on the Environment, Climate and Food Safety (ENVI). We critically assessed the Commission proposals on the 2028-2034 MFF and tried to answer the question:
Is the 2028-2034 Multiannual Financial Framework fit-for-purpose as concerns climate and environment?
Our study found that while the proposed MFF continues the mainstreaming of climate and environmental objectives across EU spending, there are critical concerns around ambition, governance and accountability. We identified several structural risks and provided tailored recommendations.
First, the single 35% climate and environment target could reduce the visibility of biodiversity-specific actions. Climate mitigation investments – often larger in scale and more readily aligned with economic priorities – may account for a substantial share of the target, which could limit the emphasis on biodiversity restoration and ecosystem protection. Instead of letting biodiversity remain a non-binding political ambition, we recommend introducing a legally binding biodiversity spending target under the next MFF.
Second, the MFF proposal continues the existing tracking methodology, which mostly applies ex-ante assessments and does not systematically verify actual outcomes or net environmental impacts. As a result, reported spending levels could overestimate real contributions, fail to capture negative externalities, and obscure trade-offs between objectives. We determined it is important to introduce outcome-oriented evaluation of climate and environment commitments, as well as introduce stricter, evidence‑based criteria.
Third, the effectiveness of DNSH and performance monitoring depends on consistent interpretation and enforcement across instruments and Member States. Limited clarity on interpretation and enforcement has reduced its effectiveness as a steering mechanism. Trinomics has been actively supporting ten Member States across the European Union, for example in Finland, to develop tailored DNSH guidance, build capacity and improve reporting under key EU financing instruments, actively addressing this lack of clarity.
To reinforce environmental integrity under the next MFF, clearer and more enforceable DNSH implementation should be pursued. This should help Member States in effectively implementing the DNSH principle across EU funding.
Last, the discontinuation of LIFE removes a dedicated, centrally managed programme focused exclusively on environment and climate action. At Trinomics we developed an ex-ante impact assessment for the post-2020 LIFE programme and supported the preparation for the current 2021-2027 LIFE programme. As such, we know its relevance as a clearly identifiable and ring-fenced funding channel, despite its relatively small share of total climate- and biodiversity-relevant spending in the EU.
Although LIFE-type activities remain eligible under the NRP Fund and the ECF, their integration into broader instruments reduces thematic visibility and distinct budgetary allocation. Put differently, climate and environmental projects will compete within larger policy frameworks oriented towards other objectives. Therefore, additional safeguards may be needed to preserve the EU added value of LIFE-type activities. These could include, for example, ensuring sufficient Member State capacity to implement high-quality projects and maintaining safeguards for EU-wide priorities alongside national programming.
While we are amid the discussions on the 2028-2034 MFF, we at Trinomics urge to consider the proposals, risks and recommendations of our study to ensure climate and environment spending is represented sufficiently under the next seven-year EU budget.
