Today we published our response to the Scottish Government Climate Change Plan Consultation. This insight summarises our response as well as explaining why good data is important in our ability to monitor fiscal sustainability. You can find our official response here.
Introduction
Today we have responded to the Scottish Government’s consultation on their draft Climate Change Plan (CCP).
Our September 2025 report on climate change set out the data, costings and methodological transparency required for effective scrutiny. Based on the information currently available, the draft CCP does not yet meet these recommendations. This Insight explains why good data matters, and why we believe more progress is needed to meet our recommendations.
Why good data on climate change matters for fiscal sustainability
Good data is essential for the Commission to be able to assess the fiscal risks of climate change.
It allows:
- accurate estimation and understanding of mitigation costs
- robust long-term fiscal projections
- identification of cross government funding risks
- monitoring of progress
Increasing clarity and reducing uncertainty and hidden risks could enable the SFC and other stakeholders to assess whether the Scottish Government can maintain fiscal sustainability while meeting its Carbon Budgets.
What data we need to assess the fiscal effects of the CCP
To meaningfully consider the fiscal implications of the CCP, we need the Scottish Government to tell us:
- How much is expected to be spent on climate mitigation in Scotland (capital and resource)
- How Scottish Government expect mitigation costs split between public and private sectors
- How the Scottish Government expect these mitigation costs to be funded
- How public sector mitigation costs align with Scottish Budget cycles.
Without this information, we cannot determine whether the CCP presents a financially sustainable path to meeting Scotland’s carbon budgets.
Assessment of the CCP
Understanding what is costed – and what is not
The plan is split between policies and proposals.
The CCP defines a policy is “where it is possible to clearly set out a specific action, scale, a lever of choice, an outcome and a timeline, and, thus, it is possible to set out clear delivery details and cost implications.”
The CCP defines a proposal is “where it is possible to clearly set out an outcome and a timeline, and it is recognised action needs to take place, generally these will have impact later in the plan period, so, consequently, more concrete detail on the precise policy levers and cost implications is more difficult to present.”
While the policies in the draft CCP are costed, the proposals are not, and the split between emissions reductions delivered by each remains unclear. This makes it difficult to understand how much it will cost to deliver the CCP.
For example, the draft CCP presents the net economy-wide costs of the policies at £4.8 billion in 2025 prices for the 15-year period the CCP covers. Based on the Climate Change Committees (CCC) latest estimates, under their balanced pathway of emission reduction, the CCC estimate a net economy-wide cost of £32.4 billion in 2025 prices over the same time period as the CCP.
Without the information about how much of the planned emission reduction is due to policies and proposals it is difficult to understand what is driving the difference. It is unclear how much of this difference is due to differing approaches to reducing emissions in the CCC’s pathway and the draft CCP, or due to the proposals being uncosted and therefore excluding part of the costs of achieving the emission reductions needed by 2040.
Public or private costs
The draft CCP only includes an estimate of economy-wide net costs. It would need to present how these costs are divided between public and private spending for us to be able to assess its impact on Scotland’s public finances.
Clarity of methods would help create transparency
The methodology used to estimate reductions in emissions and the associated costs underpinning the draft CCP are not yet clear.
As we stated in our letter, without access to methodological detail, we cannot fully assess the CCP. To understand the fiscal impact, we recommend:
- An explanation of the modelling approach used
- Clear statements of assumptions and associated risks
- Breakdown of costs by policy, sector, and year
- Publication of underlying spreadsheets and datasets.
Without this information we cannot assess the draft CCP.
Effective Monitoring
The draft CCP outlines approaches to monitoring progress on emissions and the just transition. However, monitoring the costs of policies is equally important, particularly given the scale of expected public investment.
We encourage the Scottish Government to:
- Track and publish actual public spending against planned spending
- Publish annual data on progress toward emissions reductions
- Ensure spending can be tracked through the Scottish Budget.
This level of transparency would support robust scrutiny through the budget process and help identify emerging fiscal risks at an early stage.
We understand that due to the large time periods covered in the CCP and the uncertainties related to this makes it difficult to publish definitive figures but we strongly recommend that Scottish Government publishes its latest, best estimates and that these are revised as new information becomes available.
Conclusion
Robust, transparent and comprehensive data is essential for assessing the fiscal sustainability of Scotland’s climate mitigation plans. While we recognise the tight timescales involved in finalising the CCP, the Scottish Government should publish full cost and emissions estimates information as soon as possible.