Beyond top-down: evaluating multi-level governance under the EU Governance Regulation

Extended abstract 3-140-26

The EU Governance Regulation (Regulation (EU) 2018/1999) introduced, for the first time in European legislation, a binding obligation for Member States to establish permanent multi-level Climate and Energy Dialogues (CEDs) under Article 11 – formalising the concept of Multi-Level Governance (MLG) in national energy and climate policymaking. While the Committee of the Regions' 2009 White Paper had already called for coordinated action across governance levels, Article 11 was the first hard legislative requirement to embed this in national planning cycles.

Implementing MLG represents a significant cultural shift for Member States accustomed to top-down processes and late-stage consultations. Despite nearly a decade since the Regulation's adoption, the Commission's 2025 assessment of final updated NECPs confirms persistent shortcomings: engagement with subnational authorities remains largely procedural, and few NECPs describe how stakeholder input was actually integrated into policy – as opposed to merely documenting that consultations occurred.

This contribution offers a three-part assessment of Article 11 implementation across the EU. Together, the three parts show that genuine MLG institutionalisation is achievable – but requires continuous, independently facilitated, formally anchored dialogue designed from the outset to shape, not merely accompany, policy development.

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