Submission on South Africa’s Draft Second NDC (2025) — Ensuring Ambition Is Paired With Rights-Based Delivery

Natural Justice assesses South Africa's 2025 draft NDC, acknowledging progress in absolute emissions targets but warning that these are undermined by over-reliance on international conditionality and a lack of concrete implementation plans. The submission argues that the draft fails to meet the 'highest possible ambition' standard set by the ICJ, citing gaps in adaptation financing, the exclusion of natural disturbance emissions from accounting, and the absence of a clear fossil fuel phase-out schedule. It recommends integrating a Human Rights-Based Approach (HRBA), establishing a grant-based Loss and Damage facility funded partly by a tax on fossil fuel profits, and mandating Free, Prior and Informed Consent (FPIC) for all climate projects.

• While the 2025 draft NDC improves ambition by moving to absolute emissions targets—tightening the 2030 range to 350–420 MtCO₂-eq and introducing a 2031–2035 budget of 320–380 MtCO₂-eq—Natural Justice argues this ambition is fragile due to its conditional nature and the lack of a clear retirement schedule for coal and fossil fuel infrastructure.
• The draft NDC is criticized for failing to meet the 'stringent' due diligence standard for 'highest possible ambition' as interpreted by the International Court of Justice (ICJ), particularly regarding domestic mitigation and the exclusion of natural disturbance emissions (such as wildfires and droughts) from accounting.
• Adaptation planning in the draft is deemed insufficient because major items remain marked as 'TBD' for financing, and there are no guarantees for direct funding to local governments or community-based organisations, risking a failure to deliver rights-based outcomes.
• The submission identifies a critical gap in Loss and Damage (L&D) provisions, noting the draft does not commit to grant-based, non-debt financing or establish a clear institutional mechanism for affected communities to access funds quickly and transparently.
• Natural Justice proposes that South Africa establish a domestic Loss and Damage facility funded in part by an obligatory tax on the annual profits of fossil fuel companies to internalise social and environmental costs.
• The document argues that current national policies, including the Gas Master Plan and the Integrated Resource Plan (IRP) of 2024, contradict the NDC's goals by promoting fossil fuel expansion, potentially placing South Africa on a 3.4°C warming trajectory.
• To ensure accountability and equity, the submission recommends a Human Rights-Based Approach (HRBA) that includes disaggregated reporting by gender, age, and disability, and the mandatory application of Free, Prior and Informed Consent (FPIC) for indigenous peoples and local communities.

APA

Natural Justice (2025). Submission on South Africa’s Draft Second NDC (2025) — Ensuring Ambition Is Paired With Rights-Based Delivery. https://naturaljustice.org/wp-content/uploads/2025/09/Natural-Justice-29.8.25-NDC-Comment.pdf

Chicago

Natural Justice. Submission on South Africa’s Draft Second NDC (2025) — Ensuring Ambition Is Paired With Rights-Based Delivery. 2025. https://naturaljustice.org/wp-content/uploads/2025/09/Natural-Justice-29.8.25-NDC-Comment.pdf.

Wikipedia

{{cite press release |author=Natural Justice |title=Submission on South Africa’s Draft Second NDC (2025) — Ensuring Ambition Is Paired With Rights-Based Delivery |date=2025 |url=https://naturaljustice.org/wp-content/uploads/2025/09/Natural-Justice-29.8.25-NDC-Comment.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{naturaljustice2025submission, author = {{Natural Justice}}, title = {{Submission on South Africa’s Draft Second NDC (2025) — Ensuring Ambition Is Paired With Rights-Based Delivery}}, publisher = {Natural Justice}, year = {2025}, url = {https://naturaljustice.org/wp-content/uploads/2025/09/Natural-Justice-29.8.25-NDC-Comment.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }