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

Natural Justice provides a legal and rights-based critique of South Africa's 2025 draft Nationally Determined Contribution (NDC). While acknowledging progress in absolute emissions targets, the organization argues that the draft lacks the 'stringent' due diligence required by the International Court of Justice (ICJ) and fails to provide concrete, costed implementation plans for adaptation and loss and damage. Natural Justice advocates for unconditional commitments to phase out fossil fuels, the integration of human rights indicators into monitoring frameworks, and the establishment of a grant-based domestic loss and damage facility funded by taxes on fossil fuel profits.

• South Africa's 2025 draft NDC shows progress by shifting from a Business-as-Usual trajectory to absolute emissions targets, specifically tightening the 2030 range to 350–420 MtCO₂-eq and introducing a 2031–2035 carbon budget of 320–380 MtCO₂-eq.
• The draft NDC is criticized for its over-reliance on international conditionality and a lack of a clear phase-out schedule for coal and fossil fuel infrastructure, which Natural Justice describes as 'policy incoherence'.
• Natural Justice argues that South Africa's continued reliance on fossil fuels negatively impacts public health, citing evidence that a 1% increase in lagged CO₂ emissions correlates with a 0.63% increase in child mortality in South Africa.
• The adaptation component of the draft NDC is deemed insufficient because major financing items are marked as 'TBD', and it lacks guarantees for direct funding to local governments or community-based organizations.
• The draft's approach to Loss and Damage (L&D) is criticized for not specifying the nature of international finance sought, failing to commit to grant-based funding, and lacking a domestic roadmap for the timely disbursement of funds to affected communities.
• Natural Justice identifies critical methodological gaps in the NDC, including the exclusion of natural disturbance emissions (such as wildfires and droughts) and ambiguous reporting protocols for conditional versus unconditional actions.
• To align with the 'highest possible ambition' standard set by the ICJ, Natural Justice recommends that South Africa implement an obligatory tax on the annual profits of fossil fuel majors to fund national loss and damage efforts.

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} }