The climate policy framework – Central government work on documentation and evaluation
(RiR 2025:25)
Summary
The Swedish National Audit Office has examined whether the work of the Government and government agencies on source materials and evaluations within the climate policy framework has been effective. The framework consists of climate goals, the Climate Act and the Climate Policy Council, and is one of Sweden’s instruments for fulfilling its international climate commitments. The audit covered the work of the Government, the Swedish Environmental Protection Agency and the Swedish Energy Agency on preparing source materials for climate reports and climate action plans – essential components of the climate policy framework. It also covered the Climate Policy Council’s evaluation of whether the Government’s policies are compatible with the climate goals.
The overall conclusion of the Swedish National Audit Office is that the work of the Government and agencies has several shortcomings, in particular the Swedish Environmental Protection Agency’s preparation of overall source materials for the Government’s climate reports and climate action plans. That material contains major uncertainties, which are conveyed into the Government’s climate reports and climate action plans. These uncertainties pose a risk of the difference between future greenhouse gas emissions and the long-term 2045 emission target potentially being greater than estimated by the Swedish Environmental Protection Agency and the Government. This entails a risk of the Government underestimating the need for emissions-reducing measures.
Assumptions and uncertainties in Swedish Environmental Protection Agency’s data risk depicting an overly positive and certain emission trend
The Swedish Environmental Protection Agency plays a coordinating role in agencies’ work on source materials for the Government’s climate reporting. There is a long chain of supporting material that must be interlinked and of good quality in order for climate reports and climate action plans to provide an adequate basis for decisions. However, the source materials provided by the various government agencies are not always comparable. There are considerable disparities between the views of the Swedish Environmental Protection Agency and the Swedish Energy Agency on both work on scenarios and the potential for industry to transition without any further decisions on measures. Nor is the documentation sufficiently transparent with regard to the assumptions and major uncertainties it contains. The large uncertainties in the assumptions pose a risk of the Swedish Environmental Protection Agency overestimating the overall effect of climate policy measures on greenhouse gas emissions and removals. There is also a risk of the Swedish Environmental Protection Agency depicting the future trend for greenhouse gas emissions as more certain than it actually is.
Government conveys shortcomings in agencies’ documentation into its climate reports and climate action plans
On the whole, the Government has organised the work and directed government agencies so that they can provide the Government with the supporting information it needs. However, the documentation contains deficiencies that are then conveyed into the Government’s climate reports and climate action plans, since the Government largely proceeds on the basis of the collected data submitted by the Swedish Environmental Protection Agency. Also, the Government does not always disclose the assumptions and uncertainties on which climate reports and climate action plans are based. All in all, there is a risk of the Government underestimating the need to take sufficiently effective emissions-reducing measures.
Climate Policy Council has not evaluated in detail the documentation and models for the Government’s policy
The Climate Policy Council plays an important role in the climate policy framework through its evaluation of the compatibility of the Government’s policy with the climate goals. Yet, the Council has only focused on three of the five priorities specifically outlined in this task and has not, for example, evaluated in detail the impact assessments, calculation data and models on which the Government bases its policy.
Recommendations
The Swedish National Audit Office makes the following recommendations:
To the Government
- Develop the descriptions of significant assumptions and uncertainties in climate reports and climate action plans.
- Present more potential emissions outcomes from sectors in which transition is paramount for fulfilling the climate goals.
To the Swedish Environmental Protection Agency
- Develop data for the Government’s climate reports and climate action plans by, in that material:
- clearly and coherently describing significant assumptions and uncertainties in those assumptions;
- clearly and coherently describing any discrepancies between the assessments of the Swedish Environmental Protection Agency and other government agencies responsible for climate reporting in relation to key issues, such as the pace of climate transition of industry and the significance of electricity prices for progress;
- presenting more possible emission outcomes from sectors in which transition is of key significance for fulfilling the climate goals;
- clearly reporting the methods used to prepare the documentation.
To the Swedish Environmental Protection Agency and the Swedish Energy Agency
- Expand cooperation on significant assumptions and uncertainties in the documentation that the Swedish Energy Agency delivers to the Swedish Environmental Protection Agency.
To the Swedish Climate Policy Council
- Perform all parts of task contained in the Council's instructions in terms of evaluating whether the Government’s policies are compatible with the climate goals by, also:
- evaluating the documentation and models on which the Government bases its policy;
- analysing how the climate goals can be achieved cost-effectively.