Social Climate Fund
Croatia
Overall assessment
The draft Croatian Social Climate Plan is broadly aligned with EU climate and social policy objectives and demonstrates strong coherence with the revised NECP, the Recovery and Resilience Plan, and the Long Term Building Renovation Strategy. It places a clear emphasis on structural measures to address energy poverty, particularly through investments in energy efficiency, social and affordable housing, and support for energy communities. The Plan uses an energy poverty definition consistent with the Energy Efficiency Directive and applies multiple indicators to target vulnerable households, including those not directly affected by ETS2. A key strength is the commitment to cover 100% of upfront renovation costs for the most vulnerable households.
At the same time, the Plans shows significant shortcomings in participatory governance. Public consultations were formally organised but limited in outreach, with a narrow group of stakeholders involved during drafting and no targeted efforts to engage underrepresented or vulnerable groups. Feedback from stakeholders appears to have had only marginal influence on the final design of measures, and the governance structures for implementation and monitoring lack clarity regarding stakeholder representation and accountability.
While the Plan includes credible financing and a strong investment focus, several design gaps remain, including the unclear role of one-stop-shops and intermediaries, the risk of fossil fuel lock-in through hybrid heating solutions, and the absence of cost-supportive measures to shield vulnerable households from ETS2 price impacts during the transition. Overall, the Croatian Plan provides a solid investment framework but would benefit from stronger participatory mechanisms, clearer social governance arrangements, and more robust safeguards to ensure a just and inclusive climate transition.
Detailed assessment
Public participation
Public consultation quality
The draft document was published on November 21 2025 and the consultation lasted until December 22, 2025. Every interested person could input comments for the Plan. The information on the consultation was only published on the web site of the Ministry and an e-mail was sent to people registered to receive e-mails from the public consultation platform and from this specific Ministry. No comments were submitted by December 5.
Cross-ministerial coordination & participation of social ministries
Social Ministries were involved in the process of drafting the Plan.
Stakeholder consultation scope
The measures were presented several times to the public at workshops and webinars and the online form was available on the MInistry's web page where stakeholders could enter their comments.
There was a working group established to develop the measures prior to them being presented to the wider public. A full description of the measures was not available, instead only the main features were included in a Powerpoint version.
The detailed measures only became known once the public consultation was published.
Consultation timing
Civil society organisations were in regular contact with the main drafting authority - the Ministry of Environmental Protection and Green Transition, so they were informed in advance about key milestones in the preparation of the Plan (e.g., when the drafting began) and were regularly updated on the progress.
Stakeholder representation
Only a limited circle of stakeholders were consulted during the drafting period - specifically organisations working on energy or transport poverty, and broader climate issues. Local authorities were somewhat consulted. There was no effort to reach underrepresented groups.
Stakeholder feedback integration
While civil society organisations submitted several comments during the drafting process, they were marginally taken into account.
Arrangement to set up a standing consultation/monitoring body for the Plan
Several bodies will be used to manage and monitor the implementation of the Plan:
- 1) The Plan Implementation Committee;
- 2) The body responsible for coordinating the monitoring of the Plan implementation (Coordination Body);
- 3) The body responsible for Plan measures/investments;
- 4) The body responsible for sending requests for EC payments;
- 5) The body responsible for auditing
The Ministry of Environment Protection and Green Transition will have the role of the coordinating body. Members of other bodies will be specified through separate decisions.
Involvement of Local Authorities
Local authorities were presented with the basics of the measures during the drafting period and asked for their comments.
Target groups
Energy poverty definition
The definition of energy poverty in the Plan is the same as in the Croatian Law on energy efficiency and it is consistent with the Energy Effiency Directive.
Effective targeting of vulnerable households
The Plan defines several indicators to identify energy poor and vulnerable households (income, energy performance of buildings, ability to pay bills).
The Plan however does not clearly outline what facilitation measures will be used to assist households to access funding (e.g., One-stop-shops are not clearly defined).
The measure of energy renovation of family houses states that energy certifiers will be assisting people to prepare documentation and apply to the calls for funding. Unfortunately, this excludes other organisations that have established OSSs for energy poverty and energy renovation, which is a missed opportunity.
Measures addressed to households that are not immediatedly impacted by ETS2
The Plan includes households that predominately heat their space with wood stoves.
Pass-on benefit guarantee (100% of benefits reaching vulnerable households)
The Plan includes measures that target buildings owned by state or local government who will be responsible for implementation of the investment.
Types of measures and investments
Housing sector reforms & investments
For the component of the building sector there is one measure and 3 investments defined.
- Measure M1 is related to assistance to establish energy communities;
- Investment I1: Energy renovation of family houses for households in risk of energy poverty;
- I2 Combating energy poverty in assisted areas and areas of special state concern and;
- I3 Increasing energy-efficient housing stock for social and affordable housing. Investment I3 has 3 sub-investments
- I3.1 Renovation of multi-apartment buildings owned/co-owned by public bodies for social and affordable housing purposes;
- I3.2 Adaptation and construction of energy-efficient buildings for the needs of social and affordable housing in brownfield areas and;
- I3.3 Construction of new energy-efficient apartments intended for social and affordable housing.
The Energy Efficiency First principle is not mentioned in the Plan, however, the measures themselves are oriented towards implementing energy efficiency measures as priority (such as insulation and replacement of windows and doors). One Stop Shops are not mentioned as such, however it is stated that energy certifiers will give assistance to home owners for application to public calls. It is defined that the most vulnerable households will receive 100% funding for their homes.
Heating & cooling sector reforms & investments
Measures within the building sector foresee replacement of old and inefficient heating systems with new, highly efficient ones. It is also foreseen that while refurbishing buildings, new efficient cooling systems should be installed.
Measures and investments for energy communities
The Plan includes one dedicated measure to create 10 energy communities with a budget of 4,65 M EUR.
While the measure is welcome, it could improve in ambition. 10 energy communities could likely be set up by citizens, simply by improving the registration conditions and facilitating the procedure (which is the idea of the measure) by itself / without intervention. l
The European Commission recommends that every Member State sets up at least one energy community in every municipality with more than 10,000 inhabitants.
Therefore, it's proposed for the Croatian Plan to increase its goal to at least 20 energy communities established.
Public transport & active mobility
The Plan includes the following relevant measures/investments:
- I1 Encouraging cycling in urban, suburban and rural areas and;
- I2 Improving the availability of public transport in suburban, rural and remote areas.
Vulnerable micro-enterprise support
The Plan includes only one measure targeting vulnerable micro-enterprises, which relates to support for the purchase of zero emission vehicles.
Problematic investments
The Plan states the possibility to add additional heating systems (using RES) to already existing ones, which run on fossil fuels in renovated homes.
Cost-supportive measure design
There are no cost-supportive measures defined within the Plan.
Funding sources and policy coherence
Strategic alignment & linkages with other major national strategies & plans
The Croatian Plan makes specific links with the revised National Energy and Climate Plan, the Recovery and Resilience Plan, the Strategy of Transport Development and the Long-Term Strategy for Building Renovations. However, it does not reference the National Building Renovation Plan.
The Social Climate Plan tackles some barriers and deficiencies existing in current policies and foresees to resolve them through improvement of legislation, strategies and plans.
Mobilisation of broader ETS2 revenues
The total cost of the Plan is estimated at 1.680.765.526 EUR. Of that 1.260.574.145 is allocated from the Social Climate Fund and 420.191.382 from national funds. This means that 25% is allocated form national sources (ETS2).
Additional sources for funding mobilisation mentioned are the Recovery and Resilience Plan, Cohesion Policy 2021-2027, the Just Transition Fund, the Modernisation Fund, the Innovation Fund, the Rural Development Fund, and the LIFE programme.
National expert contact: Maja Bratko, Anamari Majdandžić, DOOR; maja.bratko@door.hr, anamari.majdandzic@door.hr
Responsible drafting authority contact: Ministry of Environmental Protection and Green Transition; pisarnica@mzozt.hr