Eighteen months after the deadline passed, a quarter of the world’s nations still haven’t submitted their latest climate plans. Under the Paris Agreement, every signatory country is required to submit an updated national climate plan every five years, each one more ambitious than the last. The current round, covering targets through 2035, was due in February 2025.
As per the recent report by the Paris Agreement Implementation and Compliance Committee, 45 countries had not submitted their new Nationally Determined Contributions (NDCs) as of July 2026. Oman has since submitted its plan, leaving 44 countries still outstanding. This delay is significant because the mentioned NDCs are the core of how countries translate the Paris Agreement into national climate action.
While several countries, Kenya is among those that have submitted their new climate plans on time. Kenya submitted its Second Nationally Determined Contribution, covering the period 2031–2035, to the UNFCCC on 30 April 2025.
The headline commitment proposed by Kenya included a 35% cut in greenhouse gas emissions by 2035, measured against a business-as-usual scenario, alongside strengthened adaptation measures. The plan builds on a stack of existing domestic frameworks and was developed with a gender analysis and youth-specific consultations built into the process, according to the NDC Partnership.
The harder question here, however, does not simply lie in Kenya’s submission of its NDCs but rather whether it can afford to do what it promised.
On paper, that puts Kenya ahead of most of its peers, and considerably ahead of countries with far larger economies and emissions footprints. This is particularly important for developing countries, where ambitious climate commitments are usually met by familiar challenges such as limited domestic resources, competing development priorities as well as difficulties in accessing international climate finance.
According to Climate Action Tracker’s assessment of Kenya’s 2035 NDCs, it found that the new NDCs did not raise the level of ambition set in the earlier 2030 target.
It is recommended that the climate plans get more ambitious with each review and not just hold steady. The analysis also noted that Kenya’s projected emissions could still rise well above where the current domestic policy would otherwise take them.
The catch
The analysis also found that while Kenya’s unconditional target (the portion it commits to regardless of outside help) is broadly in line with a 1.5°C pathway, the conditional target, the more ambitious tier, contingent on international finance, is not.
In absolute terms, Kenya’s projected emissions could still rise well above where current domestic policy would otherwise take them.
That conditional/unconditional split is where the plan’s credibility will actually be decided. Kenya says it needs roughly $56 billion to deliver on the NDC in full, and a large share of that financing gap depends on money from outside the country the same international climate finance system that has consistently under-delivered on pledges made to developing nations for over a decade.
The real test
Kenya’s timely submission shows that meeting the Paris Agreement’s reporting expectations is possible. Submitting a plan on time is a procedural win; however, it is not the same as implementing it.
Kenya’s climate governance is also devolved, and county-level Climate Change Funds are meant to translate national targets into local action, which raises a further question the NDC itself doesn’t fully answer: how much of that $56 billion, if it materialises, actually reaches county governments and the communities the adaptation measures are meant to protect?
The open story here is whether the finance will show up, whether it will reach the counties on time and whether Kenya’s next progress report due under the same UN process that is currently chasing 44 other countries for their homework shows a plan that’s more than a document.
