Published: 7 April 2026. Written by: Maiju Mähönen
In December 2025, the Finnish Government adopted Finland’s long-term climate plan, which is intended to outline long-term scenarios for achieving the objectives and targets of Finland’s Climate Act. Whether the plan is in fact in line with the requirements of the Act is, however, open to serious doubt. This question is now before the Supreme Administrative Court of Finland, as Greenpeace Finland and the Finnish Association for Nature Conservation have challenged the plan in what constitutes Finland’s third climate lawsuit.
Does the plan meet the requirements of the Climate Act?
Finland’s Climate Act (423/2022) is a framework climate law that establishes Finland’s national climate objectives and sets out procedural obligations for the government to ensure their attainment. Like climate change framework laws in general, the Act itself does not mandate mitigation measures but sets the overall framework within which climate policy is to be carried out. Climate plans play a central role within this system, as they are the primary instruments through which governments must demonstrate how their actions align with the prevailing climate targets and objectives. Finland’s climate planning framework consists of four plans: the long-term climate plan, the national climate change adaptation plan, the medium-term climate plan, and the climate plan for the land-use sector, all of which have a distinct function within Finland’s climate governance architecture.
According to Section 9 of the Climate Act, the long-term climate plan must set out long-term scenarios and sector-specific pathways for achieving the objectives of the Act, including the climate targets for 2040 and 2050 as well as Finland’s carbon neutrality target for 2035. The long-term climate plan published by the Ministry of Economic Affairs and Employment in December 2025 is the first of its kind. It was issued ten years after Finland’s first Climate Act entered into force in 2015, in compliance with the Act’s ten‑year timeframe. Contrary to the wording and apparent purpose of the Act, however, the plan relies on alternative “extreme scenarios” for Finland’s climate policy trajectory, which are not realistic by their very nature. Moreover, one of the scenarios presented in the plan does not lead to the achievement of Finland’s climate targets at all (“Finland first”), while only one scenario achieves the 2035 carbon neutrality target (“Environment first”). This reflects the politics of the current right-wing government, whose second largest coalition party (Finns Party) has suggested repealing the Climate Act altogether and whose leader has dismissed the 2035 target as “absurd.”
The Finnish Climate Change Panel criticised the plan during the consultation phase, noting that the proposed pathways already appeared unlikely at that stage. It further emphasised that the plan should, on its part, promote the attainment of the targets of the Climate Act. Against this background, it is reasonable to ask whether the plan fulfils the substantive requirements laid down in the Climate Act, or whether it is more akin to a policy paper. According to the applicants, the plan in its current form breaches the Climate Act and should therefore be annulled and referred to the government for reconsideration.
How does this case differ from Finland’s earlier climate cases?
The legal challenge to the long-term climate plan differs in important respects from Finland’s two previous climate cases, discussed in more detail here and here. The earlier cases concerned governmental inaction, specifically a situation in which the government failed to apply provisions of the Climate Act relating to additional measures. These disputes were closely connected to the collapse of the carbon sink in the land-use sector and the inadequacy of mitigation measures in that sector. Although initiating a shift in the Finnish legal culture – in which the courts traditionally exercise considerable deference towards other branches of government – the first case was dismissed as inadmissible and the second on merits.
One key difficulty in those cases was that, under Finnish law, it is generally not possible to appeal against governmental inaction as such. In contrast, the present case concerns an identifiable administrative decision: the adoption of the long-term climate plan. The legal question is therefore not whether the government has failed to act, but whether it has correctly applied its statutory obligations and whether the plan meets the requirements set by law. From the perspective of administrative law, this represents a significant shift. In addition, the applicants were for the first time able to rely on the appeal provision of the Climate Act, which allows appeals on decisions concerning the adoption of climate plans. Therefore, the case is more conventional than the ones preceding it, asking the Supreme Administrative Court to fulfil its role in ensuring that the government has exercised its discretion within the limits of the law.
Climate plans before the courts: lessons from elsewhere in Europe
Finland is far from alone in seeing climate plans scrutinised by courts. Across Europe, judicial practice increasingly reflects the understanding that climate plans are not political programmes but legally relevant instruments that must comply with legal requirements. In fact, courts in several jurisdictions – including Ireland, Germany, and the United Kingdom – have found national climate plans to be inadequate. For instance, in Friends of the Irish Environment v Government of Ireland, the Irish Supreme Court annulled Ireland’s national climate plan because it did not allow a reasonable reader to understand how the government intended to achieve its long-term climate goal. German courts have likewise required the country’s 2023 climate plan to be revised on account of reliance on unrealistic assumptions and inadequate methodologies, which compromised its alignment with the Federal Climate Protection Act. In the United Kingdom, successive versions of the government’s economy-wide climate plan have equally been found inconsistent with statutory carbon budgets required by the Climate Change Act, partly due to insufficient assessment of proposed policy measures and inadequate supporting evidence. Together, these cases underline that climate plans must be both legally coherent and credible.
What does the case reveal about the direction of Finnish climate policy?
The long-term climate plan acknowledges that the next decade is decisive for Finland’s overall emissions trajectory. Yet the scenarios presented in the plan largely sideline the 2035 carbon neutrality target, implying that compliance could be ensured by postponing mitigation measures until after that date. Such an approach, however, inevitably jeopardises the achievement of Finland’s long-term climate targets as well. It also raises concerns about intergenerational equity, overlooking the fact that the equitable distribution of emissions reductions between present and future generations has increasingly been framed as a human rights concern. Furthermore, the Climate Act explicitly includes the justice of climate measures as one of its objectives, encompassing the protection of human rights and the rights of future generations. At a more fundamental level, the question is therefore not only whether the government complies with the Climate Act, but also whether it meets its broader human rights and international law obligations.
The Supreme Administrative Court now has a crucial opportunity to take a position on how the Climate Act should be interpreted. When can the content requirements imposed on climate plans be considered to have been fulfilled, and how can their alignment with climate targets be reviewed? What is the significance of the 2035 carbon neutrality target, which is based on calculations of Finland’s fair share of the global carbon budget? What is the relevance of the European Court of Human Rights’ KlimaSeniorinnen judgment, which emphasises the importance of effective implementation of legislation aimed at achieving climate neutrality? What is the significance of the Climate Act’s requirement that Finland’s climate plans also contribute to ensuring compliance with EU law, particularly in a situation where the state of the land-use sector falls short of current EU requirements? To what extent can the planning system established by the Climate Act be supplemented by a strategy adopted outside its scope, to which the long-term climate plan also refers? These are among the questions to which we now await answers from the court, whose decision will play a key role determining how binding the Climate Act ultimately proves to be in Finland.
Maiju Mähönen is a doctoral researcher at the Centre for Climate, Energy and Environmental Law (CCEEL) at the University of Eastern Finland. In line with research ethics, the author discloses her connection to the case, having supported the NGOs in the preparation of Finnish Climate Cases I, II, and III.