Sweden

Overall assessment

Only one measure - a subsidy for electric vehicles for vulnerable households - is suggested in the draft Swedish Social Climate Plan despite the possibility to also focus on public transport, shared mobility, energy efficiency and targeted support for vulnerable households. 

Moreover, a narrow interpretation of targeted groups, where non-fossil fuel dependent households have not been considered, has left approximately 100,000 households in energy poverty completely without action. This deviates from the EU's intention that energy-poor households that are not directly affected by ETS2 should also be covered. 

There are also multiple shortcomings in the one measure being presented. The electric car premium can help mitigate the effects of high fuel prices for households with limited resources, but the design needs to be tightened up to be accurate and fair. Above all, the target group should be defined more clearly, the price cap and premium level should be better justified, and the support should be linked more clearly to charging infrastructure. It is also important to gradually develop the follow-up so that climate benefit and social accuracy can be measured. 

In the longer term, Sweden should also work at the EU level to promote access to more affordable electric cars with long range, as this is a prerequisite for an electric car premium to truly reach low- and middle-income earners in both urban and rural areas.

Detailed assessment

Public participation

Public consultation quality

There are indications of the consultations having primarily been performative, with experts perceiving they have no impact to steer the direction of or planned measures in the SCP. In the invitation to comment on the final draft, the government specifically requested input on the decided measure, the EV premium, leaving no room for public and scientific comments on the overall level of ambition and actions in the SCP.

Cross-ministerial coordination & participation of social ministries

No social Ministries were involved. The SCP was drafted by the Ministry of Climate and Enterprise with support from a number of national authorities: the Swedish Environmental Protection Agency, the National Institute of Economic Research, Transport Analysis, the Swedish Energy Agency and Growth Analysis.

Stakeholder consultation scope

The official SCP website states that consultation meetings were held on 4/11/2024 and 25/4/2025. The meetings focused on the EV subsidy measure.

Consultation timing

The public consultation process was open between June 27th and September 27th 2025. Prior to that, two consultation meetings were held where specific stakeholders were invited. After the first meeting, in December 2024, the Swedish Environmental Protection Agency were handed the order by the Government to draft the SCP: "The document shall contain proposals for the design of a targeted electric car premium that reaches the target group that can receive support within the framework of the Social Climate Fund and that can be administered in an efficient manner. If necessary and following instructions from the Government Offices (Ministry of Climate and Enterprise), the document shall also contain proposals for additional measures and investments that complement the electric car premium."

Stakeholder representation

There is not enough information about who participated at the two consultation meetings. A large variety of stakeholders were however invited to respond to the final draft. Nonetheless, this final consultation provided limited possibilities to affect the ambition and actions in the SCP.

Stakeholder feedback integration

There are no indications that early stakeholder feedback has been integrated into the Draft SCP. 

Arrangement to set up a standing consultation/monitoring body for the Plan

There are no indications or official communications by the Swedish authorities that a monitoring committee will be set up for the SCP. 

Involvement of Local Authorities

The SCP website states that "On November 4, 2024, the Government organised a consultation on The Social Climate Fund with representatives from, among others, business, regions, municipalities, academia, authorities and interest groups." 

It remains unclear whether local authorities have been meaningfully included in the development of the draft SCP. 

Target groups

Energy poverty definition

The definition of energy poverty adopted in the Swedish SCP is fairly consistent with the revised Energy Efficiency Directive, although narrowly interpreted for the sake of facilitating analysis and quantification.

Effective targeting of vulnerable households

The EV subsidy is insufficiently targeted and designed. 

Drawing from the Stockholm Environment Institute's response to the SCF public consultation: "The data shows about 770,000 households as “particularly affected” by energy poverty corresponding to about 15%, which is in line with our research. However, only 105,000 or 2% of Swedish households are expected to benefit from the premium. There is no analysis of whether this is sufficient to meet the need. Variations within municipalities, such as differences in charging infrastructure and commuting distances, are not made visible but are of great importance for households’ use of electric cars in practice."

Measures addressed to households that are not immediatedly impacted by ETS2

Despite the majority of energy poor households in Sweden not relying on fossil fuels, there is no measure targeting housing/heating-related energy poverty.

Pass-on benefit guarantee (100% of benefits reaching vulnerable households)

The EV subsidy will only be paid directly to targeted households, thus ensuring a 100% pass on of benefits. 

Types of measures and investments

Housing sector reforms & investments

The Swedish draft SCP does not include any measures or reforms targeting the housing sector. 

Heating & cooling sector reforms & investments

The Swedish draft SCP does not include any measures or reforms targeting the heating and cooling sector. 

Measures and investments for energy communities

The Plan foresees no investments or reforms for energy communities. 

Public transport & active mobility

The Plan does not include any measures related to public transport and/or active mobility, despite this being raised in consultation meetings and responses.

Vulnerable micro-enterprise support

The Plan does not include any measures related to vulnerable micro-enterprises. 

Problematic investments

The only measure included in the Plan is an EV subsidy: "The target group of the electric car premium is households with lower average income, who live in a rural municipality or in an area with limited access to public transport and do not own or lease an electric car or plug-in hybrid. The electric car premium is intended to support this target group by facilitating access to electric cars. The premium makes it possible for more people to buy or lease an electric car. By using an electric car, instead of a car with a combustion engine, the recipient of the premium and their household will be less affected by the costs of fossil fuels that ETS 2 entails."

While subsidising electric mobility is not in-itself problematic, this approach disregards the potential for investments in public and active transport (e.g., trains, bike lanes). 

Cost-supportive measure design

The Plan does not include any (temporary) income support. 

Funding sources and policy coherence

Strategic alignment & linkages with other major national strategies & plans

The Swedish Plan does not make links with other national strategies, thus failing to ensure coherence. 

Mobilisation of broader ETS2 revenues

There are no such indications in the draft SCP beyond the minimum requirements that 25% of ETS2 revenues will be allocated to the Plan.

National expert contact: Stockholm Environment Institute, jenny.vonplatten@sei.org; maria.xylia@sei.org

Responsible drafting authority contact: jennica.broman@naturvardsverket.se; tea.alopaeus@naturvardsverket.se