On 30 July 2025, the Department of Forestry, Fisheries and the Environment ("DFFE") published South Africa's Draft Second Nationally Determined Contribution ("NDC") in the Government Gazette. Open for public comment until 29 August 2025, it sets out proposed climate commitments for the 2026–2030 and 2031–2035 periods. The final version will be submitted to the United Nations Framework Convention on Climate Change ("UNFCCC") ahead of COP30 in Brazil this November. The draft reflects a shift in climate policy, with new legislation, updated targets, and a stronger focus on equity and resilience.
WHAT ARE NDCS AND WHY DO THEY MATTER?
Under Article 4.9 of the Paris Agreement, countries must update their NDCs every five years. These documents serve as national climate action plans, outlining how each country intends to reduce greenhouse gas ("GHG") emissions and adapt to climate change. NDCs are central to the global effort to limit warming to well below 2°C, ideally 1.5°C, above pre-industrial levels.
South Africa submitted its Intended Nationally Determined Contribution in 2015, which became its first NDC upon ratifying the Paris Agreement in 2016. This NDC was updated in 2021, committing to a target range of 398-510 metric tonnes of carbon dioxide equivalent ("MtCO₂e") by 2025 and 350-420 MtCO₂e by 2030. The Draft Second NDC builds on this foundation and reflects evolving climate governance, shaped by recent legislative and policy developments including the Climate Change Act No. 22 of 2024 ("Climate Change Act") and the Just Transition Framework.
UNPACKING THE DRAFT
The Draft Second NDC outlines South Africa's contribution to global climate action, guided by equity, national circumstances, and the need for a just transition. It integrates climate and development priorities, aligning with the National Development Plan and the Sustainable Development Goals. The key components are:
- Adaptation: Eight national goals are proposed for 2026–2035, including water security, disaster risk management, resilient infrastructure, food systems, climate services, ecosystem-based adaptation, institutional capacity, and climate-resilient human settlements. Each goal is supported by priority interventions and tracking metrics. The Climate Change Act requires adaptation planning and reporting across all levels of government. A Just Adaptation and Resilience Investment Plan is being developed to mobilise international finance.
- Loss and Damage: The draft acknowledges the limits of adaptation and the growing burden of climate-induced loss and damage. It highlights observed impacts across sectors and calls for improved data systems, stronger institutional coordination, and international support. The Climate Change Response Fund and the international Loss and Damage Fund are identified as key financing mechanisms.
- Mitigation: The draft retains the 2030 emissions target range of 350–420 MtCO₂e and introduces a new 2035 range of 320–380 MtCO₂e. These economy-wide targets reflect South Africa's highest possible ambition, considering equity and national circumstances. The draft supports a just transition to net zero CO₂ emissions by 2050, with plans for 36 GW of renewable energy by 2035, green industrialisation, and structural economic transformation.
- Implementation: South Africa aims to quadruple its access to international climate finance to US$ 8 billion annually by 2030. The draft proposes a comprehensive financing strategy, improved monitoring and evaluation systems, and better access to adaptation finance, which currently accounts for only 12 percent of total flows. Key performance indicators will track progress in finance mobilisation, innovation, and local government access.
PROGRESS, GAPS AND GOVERNANCE
The draft reflects a maturing climate governance framework and builds on progress since the 2021 update. Emissions in 2022 were already below the upper end of the 2025 target range, indicating early movement toward a peak-plateau-decline trajectory. South Africa is on track to meet its 2025 target, fulfilling its current NDC commitment. However, analysts note that this trajectory is not aligned with a 1.5°C-compatible pathway.
While the draft incorporates several recommendations from the Presidential Climate Commission ("PCC"), it diverges in key areas. The 2030 emissions target range remains unchanged, despite the PCC's call for a downward revision. The draft also omits proposed mechanisms such as a national platform for climate finance coordination and the "Anticipate-Adapt-Recover" framework for resilience planning. These differences reflect the PCC's advisory role and the DFFE's formal mandate under the Climate Change Act.
Nonetheless, the draft includes PCC-endorsed priorities such as strengthened adaptation planning, recognition of loss and damage, and a commitment to scaling up climate finance. This selective alignment suggests a pragmatic approach, balancing ambition with feasibility while maintaining coherence with broader climate governance.
WHAT'S NEXT?
South Africa's Draft Second NDC is a detailed and forward-looking document. It reflects the country's evolving climate governance, commitment to equity, and recognition of the need for scaled-up climate finance. As the draft moves through public consultation, stakeholders have an opportunity to shape a national strategy that is inclusive, science-based, and responsive to both domestic priorities and global imperatives.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
