The Scottish Government’s draft Climate Change Plan (CCP) was published on 6 November 2025, initiating 120 days of Parliamentary scrutiny. This Plan covers the period of 2026-2040 and outlines how the Government intends to reduce greenhouse gas emissions in line with Scotland’s carbon budgets and Just Transition principles. Monitoring and evaluation (M&E) plans are set out in Annex 3 of the draft, including the structure of the CCP Monitoring Framework, the proposed emissions and Just Transition monitoring approach, analytical material underpinning the development of the CCP and a list of policies and proposals.
This blog introduces background on the M&E requirements of the Plan, approaches to M&E in previous Plans, stakeholder views on what M&E should be in the Plan, the proposed M&E approach and key areas for scrutiny. It has been produced by Dr Kirsten Jenkins, Senior Lecturer in Energy, Environment and Society at the University of Edinburgh and current Adviser on climate change and net zero targets to the Net Zero, Energy and Transport Committee. As with all guest blogs, what follows are the views of the author and not those of SPICe, or of the Scottish Parliament.
For more blogs on other topics relating to the draft CCP, visit the SPICe Hub on the draft Climate Change Plan.
Monitoring and evaluation requirements and reporting
The statutory requirements for the draft CCP are discussed in a recent SPICe blog. In relation to M&E, Section 33 of the Climate Change (Scotland) Act 2009 mandates statutory monitoring of Scotland’s climate progress, requiring Scottish Ministers to publish an annual progress report detailing policy implementation and sector impacts alongside broader reports on emissions trends and carbon budgets.
Prior to the 2025 draft, the last full full CCP was laid in 2018, with a Climate Change Plan Update (CCPu) published in 2020.1 Annual progress reports with sector-by-sector detail have been published regularly since 2021. The fifth annual monitoring progress report on the CCPu was published in May 2025.
Approaches, strengths and limitations to M&E in previous Plans
A range of governance arrangements are in place to help ensure the Scottish Government’s accountability in the delivery of the CCP. Primary scrutiny responsibility sits with the below, though a wider range of stakeholders feed in:
- Climate Change Committee (CCC), an independent, statutory body, which advises the Scottish government on emissions targets and reports to the Scottish Parliament on progress made in reducing greenhouse gas emissions and preparing for and adapting to the impacts of climate change.
- Audit Scotland (AS), provides independent public audit, reporting on how the Scottish public sector is responding to the climate emergency and how public money is being used to help achieve Scotland’s climate change ambitions.
- Environmental Standards Scotland (ESS), an independent public body, which was set up to ensure the effectiveness of environmental law and prevent enforcement gaps arising from the UK leaving the European Union.
- The Scottish Parliament.
Previous iterations of the CCP, including the CCPu, have been criticised for their M&E approaches. In 2023, the Auditor General for Scotland (AGS) published “How the Scottish government is set up to deliver climate change goals: Governance and risk management arrangements for net zero targets and adaptation outcomes” (see also a SPICe blog on climate change and the Public Audit Committee). The report states:
“Given the urgency, further improvements to key aspects of governance are required… The lack of frequent and consistent reporting, alongside gaps in performance monitoring, make it difficult to gain assurance of overall progress.”
A 2024 joint briefing from the Environmental Rights Centre for Scotland (ERCS) and Stop Climate Chaos Scotland (SCCS) notes:
“Our assessment of the evidence highlights the importance of a rigorous and transparent approach to data monitoring, reporting, and assessment of progress towards delivery. Such an approach might have avoided recent policy failures. Forthcoming legislation and the new CCP are opportunities to embed improved monitoring, reporting, scrutiny and transparency”.
In 2024, ESS reviewed existing scrutiny of past CCPs to identify themes and issues and make recommendations in areas where ESS may consider using enforcement to pursue improvement. Their summary report raised concerns around the effectiveness of the Scottish Government’s monitoring and delivery of proposals and policies.
ERCS and SCSS say that there were “critical failures to comply with legal requirements in the production of the last Plan” – a problem they argue could be repeated unless the new framework builds in robust public scrutiny, reporting and assessment. They highlight the need for effective enforcement and clearer accountability, including clear consequences if climate or just-transition milestones are missed.
The Environment Climate Change and Land Reform Committee (ECCLR) (predecessor to the Net Zero, Energy and Transport (NZET) Committee) report on the CCPu recommended at the time that the final CCPu should provide:
“… clarity in delivery and implementation, setting out clearly: where responsibilities lie, what commitments are in place and specific timescales for delivery – as the Committee recommended previously, policies and proposals need to be SMART – specific, quantified and time-bound.”
None of the recommendations made by the ECCLR committee were reflected in the final CCPu. The then Cabinet Secretary for Environment, Climate Change and Land Reform stated that:
“At the point of receipt of the Committees reports, there was only 2 working days until the debate and 13 days to the start of the pre-election period. This necessarily shapes the nature of the Government’s response in this instance, as does the fact that this is an update and not a full Plan.”
Stakeholder views on M&E approaches: what should be in the Plan?
In advance of the publication of the draft CCP, the NZET Committee undertook a proactive Call for Views (CfV) (full responses are published on the Scottish Parliament website). The CfV asked questions on various aspects, including how the Scottish Government could ensure transparent monitoring and reporting on progress. In advance of the Draft Plan being published, the NZET Committee also sought views from AS, the CCC, ESS and the Scottish Fiscal Commission (SFC) on what a ‘good’ CCP would look like. Key M&E issues are set out below.
Transparency and accountability
Stakeholders noted a need for transparency and accountability, including robust frameworks to monitor emissions reductions, capture wider benefits and enabling actions, and set out clear ownership of actions, reporting responsibilities and governance structures.
The Royal College of Physicians Edinburgh: Air Pollution Working Group and Climate Café stated that “transparent monitoring builds trust, accountability, and public engagement, which are essential for delivering the Climate Change Plan (CCP).” In the UK Energy Research Centre response, Dr Mark Winskel of the University of Edinburgh noted:
“Transparent monitoring and reporting on progress in critical for policy delivery and societal legitimacy needed for Net Zero delivery, especially at a time of heightened political contention.”
In CCC’s letter to NZET in March 2025, they stated:
“To enable effective scrutiny and support collaborative efforts between the Scottish Government, businesses, and the public, the Scottish Government should be transparent in this monitoring and evaluation. This can allow for early identification of potential issues before they translate into impacts on emissions trajectories.”
Dynamic and adaptive approaches
Stakeholders highlighted a need for dynamic and adaptive approaches, focused on an agile, responsive, targeted, and effective approach to delivery of the aims, benefits and outcomes of the CCP. This included calls for risk-based approaches that highlight emerging challenges (including stalled emissions reduction) early, and support policy revision as new data emerges to improve the Plan over time – including via SMART (Specific, Measurable, Achievable, Relevant, Time-bound) indicators, and live or regularly updated policy lists.
The Scottish Climate Intelligence Service stated that:
“To measure and adapt to progress, and to respond to external opportunities and challenges, the plan needs to be monitored and adjusted in a way that allows us to change priorities, mark off actions, and incorporate new technologies, solutions, and actions as they become proven and available… Establishing a live and updated list of policies and interventions to apply, supported by a dynamic monitoring process, would support more agile and effective planning and delivery, allowing revision of the plan in response to progress, insights, and emerging opportunities.”
The Climate Emergency Response Group (CERG) emphasise that the CCP must be a plan for delivery, with significant attention given to the data and evidence base to track progress and results. In their September 2025 report, “Embedding delivery in Scotland’s Climate Change Plan”, CERG wrote:
“Monitoring must evolve from focusing only on the ‘time-lagged’ impact indicator of emissions reduction, but also to test (as close to real-time as possible) whether interventions are effective and the system is starting to ‘shift’, allowing for course correction where needed”.
The CCC, ESS and AS stated that a framework needed to be able to assess if progress is on track. ESS called for “proactive review of the implementation and efficacy” of measures’, including interim measures and targets and a “set of performance and output indicators that provide more immediate feedback on progress.” SFC set out that tracking of policies and spending decisions in the Budget would allow them to “monitor the risks to fiscal sustainability.”
ESS and the CCC also suggested that contingency plans for a rapid response to issues would be helpful, with ESS noting there should be details on how emission deficits and surpluses are managed across five-year terms. Contingency planning for certain sectors was also recommended by the ECCLR committee in their scrutiny of the 2021 CCPu.
Stakeholders also called for:
- Monitoring to be understandable and accessible to the public, including visual tools and infographics, public dashboards (showing, for instance, emissions progress, co-benefits, enabling actions and regional breakdowns) and clear explanations of progress. For example, Dr Lea Raible and colleagues at the University of Glasgow noted the requirement for “timely, useful and adequate access to environmental information for individuals and relevant stakeholders.”
- Monitoring frameworks that include co-benefits (such as health, equity, jobs and biodiversity) and indicators that capture distributional impacts and demonstrate the wider value of climate action. For example, the Scottish Environmental Protection Agency noted that “co-benefits are an important component of a just transition to net zero and therefore should be included within the monitoring and reporting framework.”
- Independent oversight and scrutiny, including strengthened scrutiny functions for pre-existing groups and mechanisms to audit government spending and ensure consistency with statutory targets. For example, some stakeholders called for an independent body like the CCC or a Scottish equivalent to oversee monitoring, or for an extension to the remit of the Scottish Government’s Climate Change Plan Advisory Group.
- Integration with local data and existing reporting systems, some stakeholders highlighted the capacity burden of detailed reporting and called for support, including for national monitoring efforts to be aligned with Local Authority data systems and Public Bodies Climate Change Duties. There were also calls to maximise the potential of systems like ClimateView, which standardise and visualise local data.
In a letter to the NZET Committee in December 2025, the AGS stated that:
“Finalising the monitoring and evaluation framework in time to assess progress during the first five-year carbon budget period will be important. Until the framework proposed in the draft CCP is developed, it is not possible to assess how effective it will be in supporting scrutiny of progress or in highlighting risks to delivery early enough to enable the Scottish Government to take effective corrective action, if needed.”
The proposed approach
Annex 3 of the draft CCP introduces the Scottish Government’s approach to M&E the policies and proposals set out in the draft CCP. The Monitoring Framework is structured around three key areas, two related to Greenhouse Gas (GHG) emissions and one related to Just Transition:
- National, sectoral and sub-sectoral GHG emissions monitoring. Annual emissions data will be published via annual GHG Inventory Emissions Statistics, published every June with an approximately 18-month time lag.
- Early-warning indicators. Given the time lag associated with GHG inventory data, the draft CCP states that a system of emissions-reduction early-warning indicators will be developed and monitored for each sector.
- Just transition indicators. For the first time, the CCP monitoring framework also includes a set of just transition indicators, to be reported on annually alongside progress on emissions reduction.
Emissions reduction indicators
A two-track process is proposed to monitor emissions reduction: (1) annual emissions output relative to the total envelope required to achieve the five-year carbon budget; and (2) early warning indicators.
Annual emissions output will be monitored as follows:
“… emissions pathways have been produced for every major source of sub-sectoral emissions. These pathways inform the rate at which each source of emissions is expected to decarbonise and will be used to formulate sub sectoral outcomes. When summed together, these pathways form the total sectoral emissions envelope and when aggregated across sectors, the overall carbon budget. Each year, when Greenhouse Gas Inventory data is published, we will report output 3 emissions at the sub sectoral level relative to their respective carbon budget envelopes.”
As the CCP’s monitoring report is published each May, there will be a three-year lag in reporting emissions outcomes. Therefore, early warning indicators are proposed as a response to tracking progress without a data reporting time lag.
Indicators are currently used as part of the CCPu M&E across the sectoral categories of Electricity; Buildings; Transport; Industry; Waste; Land Use, Land-use Change and Foresty, and Agriculture (for example, percentage reduction in car kilometres and total amount of landfilled waste in tonnes). However, the draft CCP does not specify the new indicators in detail or the process for their development:
“The indicators used to monitor progress in decarbonising each source of emissions will depend on data availability and the complexity of the policy package underpinning each respective sub sectoral emissions pathway. Some indicators from the existing monitoring report will be retained where they remain relevant, while new indicators will be introduced where necessary and where data availability allows to capture the impact of updated policies and priorities.”
Just Transition indicators
The draft CCP is the first to include Just Transition Indicators, reflecting a legally binding commitment to a Just Transition set out in the Climate Change (Scotland) Act 2009, as amended. The Act introduces the “just transition principles” as the importance of taking action to reduce net Scottish emissions of greenhouse gases in a way which:
- supports environmentally and socially sustainable jobs
- supports low-carbon investment and infrastructure
- develops and maintains social consensus through engagement with workers, trade unions, communities, non-governmental organisations, representatives of the interests of business and industry and such other persons as the Scottish Ministers consider appropriate
- creates decent, fair and high-value work in a way which does not negatively affect the current workforce and overall economy
- contributes to resource efficient and sustainable economic approaches which help to address inequality and poverty.
The proposed CCP indicators are grouped into four outcome themes:
- Communities and place
- People and equity (spatial and financial)
- Jobs, skills and economic opportunities and
- Environment and biodiversity.
There are 14 indicators, including processed focused (e.g., “participation in decision making”), issue focused (e.g., “fuel poverty”), stakeholder focused (e.g., “impact on household finances in oil and gas communities”) and environment focused (e.g., air pollution). They have been developed through successive years of Scottish Government work, input from the Just Transition Commission and a funded Scottish Government Research post.
The proposal is for “these CCP just transition indicators to form part of a full just transition M&E framework, which will sit separately to the CCP and CCP M&E process.” They will be reported on annually to track progress on whether a just transition is being achieved alongside progress on emissions reduction pathways. The draft states that:
“The indicators proposed below aim to address this need by combining metrics that provide a single whole-of-Scotland measure with those that focus on specific sub-groups of the population, including:
- Communities and workers facing significant impacts as a result of their close connections with particular carbon intensive industries.
- Places with significant local net zero infrastructure and land use change
- Differentiated rural, urban and island community impacts
- Businesses.”
The draft CCP also acknowledges that the proposed approach to monitoring the Just Transition is limited:
“We know that it is not possible for a small set of metrics to provide a complete assessment of whether we are delivering a just transition for Scotland. The proposed indicators are inevitably partial and cannot capture the complex, dynamic and multi-layered range of outcomes that the Scottish Government has identified for Scotland’s wider just transition. As such, a project is currently underway to develop a more comprehensive just transition M&E framework through a staged process of evidence review, stakeholder engagement and cocreation… The inclusion of these core indicators in the CCP will very much be a first step.”
There is no information in the draft CCP on how these indicators have influenced CCP policies and proposals; it appears that they primarily serve to monitor and evaluate Just Transition outcomes rather than inform policy development.
Annex 4 of the draft CCP introduces consultation questions divided by sector and theme, with a closing date of 29 January 2026. Section 5; Monitoring emissions reductions and Section 6: Monitoring Just Transition cover areas directly relevant to M&E. For example, views on M&E reporting, the utility of annual indicators, and the specific Just Transition indicators – including for public participation and community impact.
Does the draft Plan measure up?
Some commentary on the draft CCP has already been published, including through Parliamentary committee evidence sessions (including at the time of this blog, the NZET Committee and the Local Government, Housing and Planning Committee). Much of the discussion follows the themes outlined above, including transparency and detail, timescales, and the development of early warning indicators. A recent blog by SCCS critiques the approach set out in the draft CCP:
“The CCP clearly purports to provide monitoring and analysis, but the detail is limited – broken down only to outcome or policy package level. And there is buck-passing in most sections, relying on ‘asks’ from the UK government, local authorities and non-government partners such as businesses.”
In evidence to NZET on 25 November, Neil Langhorn (ESS) welcomed early warning indicators but noted:
“That is a great idea in principle, but the level of detail is not there at the moment… In two or three years’ time we will want to ascertain whether we are on track with the plan, but I am not clear as to exactly how we would assess that.”
The AGS’s letter to NZET in December highlights that for effective monitoring and reporting of progress, the CCP needs to identify the timescale for implementing each policy and for expected emissions reductions. It states that:
“The lack of clear and specific timescales means that it is not obvious what the Scottish Government’s priorities are in the short-term (i.e. over the first carbon budget period)… Finalising the monitoring and evaluation framework in time to assess progress during the first five-year carbon budget period will be important. Until the framework proposed in the draft CCP is developed, it is not possible to assess how effective it will be in supporting scrutiny of progress or in highlighting risks to delivery early enough to enable the Scottish Government to take effective corrective action, if needed.”
Comparing stakeholder views on what should be in the Plan with early commentary and scrutiny of the approach set out in the draft Plan, a number of areas for further scrutiny emerge, set out below.
Just Transition: It remains to be seen how feedback on the current proposed just transition indicators will be used to develop a full just transition M&E framework. Questions include the timeline for its development, how and when data will be published, and whether all relevant data are available.
Early warning indicators: Areas for further consideration include processes for the development and delivery of the early warning indicators, as well as their ongoing review.
Incomplete data: The inclusion of indicators that capture just transition dynamics and wider co-benefits is welcomed by a range of stakeholders. However, some data (especially on participation and community-level effects) are not yet collected, raising questions about feasibility and reliability of new methods. There are also concerns around consistency of collection, data reliability, and whether the right metrics will be tracked over time. Local Authorities and other public bodies have raised concern over sufficient resources, data collection mechanisms, and administrative capability to deliver consistent reporting. Areas for scrutiny may include governance and accountability structures to manage reporting duties and overcome partial datasets, as well as the proposed methodologies for data collection.
Transparency and public accessibility: There are questions about how the Scottish Government intends to communicate M&E findings and governance arrangements to ensure transparency accountability.Relevant consideration includes matching indicators to policies and proposals and mechanisms for public communication of data and findings.
Timescales: Clear policy timelines enable M&E in that they set the milestones against which progress and impacts can be assessed. In this context, areas for scrutiny include whether the lack of detailed timelines for some policy proposals will influence their monitoring.
Adaptability, delivery and accountability: M&E insights can be used as a mechanism to take corrective action, by signalling where emissions reductions may be off track in relation to budget envelopes, or if there are failures in policy deliverability. Areas for scrutiny include the governance and accountability processes related to M&E, and how monitoring data will be used to inform adaptive approaches.
After the 120 days of parliamentary scrutiny of the draft CCP, the Scottish Government will only have a few weeks to integrate any recommendations and feedback into the final CCP before the dissolution of Parliament. A fit-for-purpose M&E framework will be critical as what is in the Plan will be delivered in the new Parliament, possibly with a new government, and against carbon budgets that have been set to 2045.
Dr Kirsten Jenkins, University of Edinburgh
Featured image by Professor Ed Hawkins, University of Reading.
- The CCPu was labelled an ‘update’ rather than a full Plan and was therefore not required to adhere to the new requirements set out in the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019. ↩︎