2035 NDC
2035 NDC Target
Disclaimer: We have updated the “2035 NDC” tab of this country assessment. Some numbers included in the tab may differ from the rest of the assessment due to recent updates in our methodologies and a switch in Global Warming Potentials from the AR4 reporting standard to AR5. These differences will be reconciled in our next full country assessment for Kenya. The rest of the country assessment sections remain as published in the last country update (May 2022).
Kenya's new 2035 NDC commits to a 35% reduction in emissions by 2035 below business as usual (BAU) scenario. In absolute terms, emissions under this NDC would rise significantly, exceeding current policies. Kenya’s reliance on a BAU scenario target, coupled with the Kenian government’s stated right to revise it, raises concerns about accountability and transparency and risks undermining ambition if the baseline is adjusted upwards. The NDC does not commit to a fossil fuel phase-out and lacks clarity on the role of LULUCF. Kenya may consider selling emissions reductions under Article 6, which risks undermining ambition if the credits do not represent real, additional and permanent reductions.
Kenya’s 2035 unconditional target is 1.5°C-compatible compared to Kenya’s fair share, but it is moving closer to the top end of that range, compared to the 2030 target (i.e. closer to the limit with the 2°C), which is not a positive development. Kenya’s conditional 2035 target is no longer aligned with a 1.5°C pathway. In short, Kenya’s 2035 NDC represents a missed opportunity to reflect the level of ambition needed to address the climate crisis and would benefit from being strengthened to include a clearer commitment to real, measurable emissions reductions.
Kenya | 2035 NDC target |
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2035 unconditional NDC target | ||||
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Formulation of target in NDC |
Kenya endeavours to abate its GHG emissions by 35%, or 75 MtCO₂e, relative to the business-as-usual (BAU) scenario of 215 MtCO₂e (including LULUCF) in 2035. Subject to national circumstances, Kenya will mobilise domestic resources to realise 20% (15 MtCO₂e) of the emissions reductions. |
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Absolute emissions level in 2035 excl. LULUCF |
Level of emissions to be achieved at home (domestic target component) 169 MtCO₂e 160% above 2010 levels |
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Status | Submitted on 30 April 2025 |
2035 conditional NDC target | ||||
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Formulation of target in NDC |
Kenya endeavours to abate its GHG emissions by 35%, or 75 MtCO₂e, relative to the business-as-usual (BAU) scenario of 215 MtCO₂e (including LULUCF) in 2035. The remaining 80% (60 MtCO₂e) of the emissions reductions will be achieved through international support, such as climate finance, foreign investment, technological development and transfer, capacity building, and participation in carbon markets. |
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Absolute emissions level in 2035 excl. LULUCF |
118 MtCO2e 82% above 2010 levels |
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Status | Submitted on 30 April 2025 |
Ambition
For the world to have a significant chance of limiting warming to 1.5°C, governments must switch to emergency mode and strengthen both their 2030 targets and current policies to include substantial emissions cuts and significantly contribute to closing the 2030 emission gap. Kenya’s submitted 2035 NDC target did not increase the ambition of its 2030 target.
2030 NDC target
2030 unconditional NDC target | 2030 conditional NDC target | |
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Is the target 1.5°C compatible compared to modelled domestic pathways? |
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Is the target 1.5°C compatible compared to fair share? |
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️ ** |
Is this a stronger target than previously submitted? |
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2035 NDC target
2035 unconditional NDC target | 2035 conditional NDC target | |
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Is the target 1.5°C compatible compared to modelled domestic pathways? |
️* |
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Is the target 1.5°C compatible compared to fair share? |
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️** |
Does the NDC include sectoral targets? |
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Does the NDC include a renewable energy capacity target? |
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Does the target align with the country’s net-zero pathway? |
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* According to our methodology, for developing countries we only compare the conditional target to our modelled domestic pathways.
** According to our methodology, for developing countries we only compare the unconditional target against fair share.
Kenya submitted its 2035 NDC on 30 April 2025, committing to abate GHG emissions by 35% by 2035 relative to a BAU scenario of 215 MtCO2e in 2035. 20% of this reduction will be achieved domestically with Kenya’s own resources (the unconditional component of the target), which translates into an emissions level of 200 MtCO2e by 2035 (incl. LULUCF).
The remaining 80% reduction is to be achieved with international support (the conditional component of the target) and would reduce emissions to 140 MtCO2e (incl. LULUCF) in 2035. The 2035 NDC covers all sectors and all relevant gases. The previously submitted, 2030 NDC put forward an unconditional target of 133 MtCO2e and a conditional target of 97 MtCO2e by 2030 (incl. LULUCF).
The CAT evaluates NDC targets excluding emissions from land use, land use change and forestry (LULUCF) to keep the focus on emissions from fossil fuel combustion and other relevant sectors, and because of the often-large uncertainty in estimates of LULUCF emissions and removals. This uncertainty is especially relevant because the LULUCF sector makes up nearly half of Kenya’s total emissions. According to our calculations, Kenya’s unconditional 2035 target translates to an emissions level of 169 MtCO₂e and the 2035 conditional target to 118 MtCO₂e, both excluding LULUCF (see Assumptions).
When measured against its fair share of global climate action, Kenya’s unconditional target of 169 MtCO2e (excl. LULUCF) in 2035 is 1.5°C compatible. This will lead to emissions being 56 MtCO2e higher in 2035 (excl. LULUCF) than in 2030 NDC. Kenya is moving closer to the top end of their current 1.5°C rating under fair share, closer to the 2°C or “almost sufficient” rating, decreasing rather than increasing ambition over time.
The conditional NDC target of 118 MtCO2e in 2035 is not 1.5°C compatible compared to modelled domestic pathways. To reach that level, Kenya would need to reduce its emissions excluding LULUCF to below 84 MtCO2e in 2035, to be achieved with climate finance and other international support.
Kenya’s reliance on a BAU scenario to define its emissions reduction targets, coupled with its stated right to revise it, raises concerns about accountability and transparency and risks undermining ambition if the baseline is adjusted upwards. Kenya’s NDC should instead rely on a clear, absolute and ambitious emissions reduction goal.
Kenya's 2035 NDC will lead to emissions levels higher than those estimated under current policies. According to our calculations, the unconditional NDC will lead to emissions 42–53% higher than our current policy projections for 2035. Even with full international support to meet the conditional target, Kenya’s emissions level would still be right at the limit or slightly above the upper end of our current policy projection, highlighting a missed opportunity for additional climate mitigation efforts.
The 2035 NDC includes several key mitigation initiatives, including reaching 100% renewable energy in power generation by 2035, increasing tree cover through reforestation and agroforestry, and transitioning to low-carbon systems in the industrial, transportation, waste, and agricultural sectors. While the 2035 NDC does not include specific sectoral reduction targets, it refers to the Third National Climate Change Action Plan (2023–2027), which provides emissions reduction potential relative to BAU for all sectors of the economy up to 2030. If Kenya were to publish a similar sectoral target list for 2035, our assessment above would change from a yellow dash to a green tick.
Further information on Kenya’s 2035 target can be found here.
KENYA | Target summary (excluding LULUCF) |
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2030 target: Emissions compared to 2010 levels (CAT estimates) | |
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Current policies in 2030 | 61-67% above |
2030 unconditional NDC target | 74% above |
2030 conditional NDC target | 27% above |
1.5°C compatible fair share | 145% above |
1.5°C compatible modelled domestic pathway | 30% above |
2035 target: Emissions compared to 2010 levels (CAT estimates) | |
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Current policies in 2035 | 71-84% above |
2035 unconditional NDC target | 160% above |
2035 conditional NDC target | 82% above |
1.5°C compatible fair share | 184% above |
1.5°C compatible modelled domestic pathway | 29% above |
Note: due to the change in reporting standards for greenhouse gas global warming potentials (GWP) from AR4 to AR5, the estimates above differ from the full assessment for Kenya dated May 2022 and these differences will be reconciled in our next full country update. Please see the Assumptions section below for more details.
Fairness & Finance
Developed countries need to significantly scale up international climate finance and other means of support. Developed countries should set 1.5°C aligned domestic mitigation targets in their NDCs and communicate the financial and other support they will provide to developing countries. Developing countries should clearly communicate the climate finance they need to set and achieve ambitious 1.5°C aligned conditional targets.
2035 unconditional NDC target | 2035 conditional NDC target | |
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Does the target clearly communicate the climate finance and support needed to reach the conditional target? |
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Most developing countries will need financial support to mitigate emissions beyond what would be their fair share according to effort-sharing frameworks. Therefore, the CAT encourages these governments to put forward an ambitious conditional target that is in line with their 1.5°C modelled domestic pathway, and to quantify climate finance needed, including an implementation plan, to meet the set target.
Kenya estimates that the cost of fully implementing its proposed mitigation measures for the 2031-2035 period is USD 22.5 billion. Kenya intends to provide 19% (USD 4.28 billion) of the mitigation cost from its own domestic resources, with the remaining 81% (USD 18.34 billion) coming from international support. These estimates may change with national circumstances and Kenya intends to develop a comprehensive investment plan to guide the distribution of resources across its climate actions.
Kenya’s conditional NDC target for 2035 is not 1.5°C compatible compared to modelled domestic pathways.
Credibility
Credible NDCs should build on robust national planning processes that translate the economy-wide emissions reduction target into action in all sectors. Governments need to ramp up the implementation of their existing targets and further develop policies to close the – still significant – emissions gap between current policies and a 1.5°C pathway. Contradictory policies must be addressed and reversed: fossil fuel production needs to be phased out, while fossil fuel exploration and fossil fuel subsidies need to stop.
2035 unconditional NDC target | 2035 conditional NDC target | |
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Is the target aligned with current policies AND driving more ambitious action? |
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Does the NDC reference national planning processes for its development? |
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Does the NDC reference an institutional framework/plan in place for its implementation? |
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Does the target commit to phase out fossil fuel production? |
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Does the target commit to stop fossil fuel exploration & subsidies? |
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Kenya's 2035 NDC would lead to emissions above our current policy projections. The BAU scenario in 2035 is estimated at 215 MtCO2e, between 80-94% higher than our estimates under current policies for 2035. Even with full international support to meet the conditional target of 118 MtCO2e in 2035, Kenya’s emissions level would still be above the lower end of our current policy projections, raising concerns about whether this NDC is a credible attempt to bend Kenya’s emissions trajectory towards decarbonisation.
Kenya’s 2035 NDC builds on existing national policies, legal frameworks, and sectoral strategies, including the Kenya Vision 2030, the Climate Change Act, the National Climate Change Action Plan (NCCAP) III, and the Long-Term Low-Emission Development Strategy (LT-LEDS).
The 2035 NDC acknowledges Kenya’s consideration of exploiting fossil fuel resources, such as oil and coal for its energy expansion plans, highlighting the environmental and social impacts associated with fossil fuels. The NDC emphasises the importance of a just energy transition, the need for significant international support, and the prioritisation of renewable energy sources to meet climate goals. However, the 2035 NDC does not commit to phase out fossil fuel production.
Transparency
Governments should set absolute, economy wide, emission reduction target trajectories including all GHG gases, specifying the emissions levels for each year as an absolute level of emissions (excluding LULUCF) so they are clear, transparent, and immune to creative accounting. NDC targets should primarily focus on their domestic reductions by decarbonising all sectors of the economy rather than relying on forestry sinks, other carbon dioxide removal (CDR) or international carbon markets.
2035 unconditional NDC target | 2035 conditional NDC target | |
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Is the target based on fixed, absolute values? |
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Does the target cover all sectors? |
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Does the target cover all greenhouse gases? |
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Does the target specify an emissions pathway? |
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Does the target separate out land use and forestry? |
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Does the target separate out other CO2 removal by type? |
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Does the target separate out the use of carbon credits? (Article 6) |
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Kenya’s 2035 NDC is stated as a conditional and unconditional reduction from an estimated BAU level in 2035 but acknowledges that it may recalculate the 2035 BAU level in the future. While such a revision may be understandable in the context of Kenya, where monitoring, reporting, and verification (MRV) systems are still developing, it is important to note that this mechanism could be used for Kenya to move the goalposts on its mitigation targets without taking real action.
Kenya’s 2035 NDC covers all relevant greenhouse gases and sectors of the economy. However, Kenya notes that F-gases, which are currently negligible, may be included in the NDC. Since emissions from Kenya’s industrial processes sector are growing quite quickly and are associated with these gases, Kenya could ensure their inclusion in the NDC.
The new submission does not specify how much of the target will be achieved using removals from the LULUCF sector. This is particularly important because the LULUCF sector makes up nearly half of Kenya’s total emissions, per the latest emissions inventory. The share of expected LULUCF emissions (or removals) also has implications for the level of decarbonisation required for other sectors of the economy. According to our guidelines for a good NDC, any contribution of the LULUCF sector, engineered and novel types of carbon dioxide removal (CDR) or international carbon markets under Article 6, should be stated separately.
Kenya plans to use both market and non-market mechanisms under Article 6 and sell emissions reductions if it overachieves its NDC. This poses a risk, as our analysis shows Kenya’s unconditional 2035 NDC target is set above current policy projections, meaning that any reductions Kenya might sell may not be truly ‘additional’. Under Article 6, credits must represent real, additional and permanent reductions, yet BAU-based targets like Kenya’s, could result in inflated baselines and over-crediting.
For more information, on Kenya’s climate targets and policies, please click here. For the CAT’s full recommendations for setting NDC targets that form the basis of the analysis above, please click here.
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