Governmental Greenwashing? Adding some much needed context to the New Zealand Government’s statements at climate negotiations
Over the last few weeks, governments have been convening in Bonn, Germany, for the latest rounds of United Nations climate negotiations. New Zealand presented on 12 June 2026. On the surface, many of the claims made sound promising. But when you lift the hood, the full picture is not presented.
Below, we put some of the New Zealand Government's claims into context, focusing on the abatement gap and New Zealand’s support for a 1.5°C-aligned framework. These are just two examples of an increasingly pervasive governmental version of 'greenwashing' on the international stage.
The NDC1 abatement gap
Abatement gap refers to the shortfall between a country’s projected domestic greenhouse gas emissions and the reductions it has committed to under the Paris Agreement, called Nationally Determined Contributions (NDC). New Zealand’s presentation reported that our first NDC (spanning from 2021 to 2030) (NDC1) currently has an abatement gap of 89.2 Mt CO₂-e. The presentation notes that this figure "does not include the impact of more recent policies such as those outlined in ERP2”, referring to the Government's Second Emissions Reduction Plan published in December 2024.
To meet this abatement gap, the Government says it is "exploring options for international cooperation" but "continues to prioritise domestic action to meet our NDC1."
What’s under the hood?
It's important to note at the outset that the “impact of more recent policies such as those outlined in ERP2” is only 3.2 Mt CO₂-e of abatement, leaving a gap of approximately 86 Mt CO₂-e to meet NDC1.However, much of the abatement projected in ERP2 will no longer eventuate, due to both policy rollbacks (for example, the pricing of agricultural emissions) and a carbon capture and storage project that has now been dropped from MfE's 2025 emissions projections after Todd Energy confirmed it would not proceed. Regardless of whether the actual gap is closer to 86 or 89 Mt CO₂-e, it's significant. For scale, that is more than New Zealand's total gross emissions in 2024 (being 75.81 Mt CO₂-e).
The Government has stated that it plans to close the gap by prioritising domestic action and exploring options for international cooperation. But there are clear reasons to doubt this.
“Prioritising domestic action” is not an accurate reflection of the Government’s actions:As just a few examples, over the past 18 months, the Government has:
wound back the Clean Car Standard and other transport mitigation policies;
made decisions that have caused the NZU price in the NZ ETS to fall sharply, including removing the requirement that the NZ ETS settings “accord” with our NDCs. The Climate Change Commission subsequently reported that they have received “universal feedback [that] this announcement had undermined market participants’ confidence in the Government’s commitment to the NZ ETS” and that it was part of a wider series of earlier decisions that market participants “perceived as weakening other aspects of climate policy”;
introduced new fossil fuel subsidies and doubled down on procuring an LNG Import Facility.
And exploring options for international cooperation seems to be an ambitious understatement of the action the Government actually needs to take:
The Government has pointed to three letters of intent and memoranda of understanding with Indonesia, Viet Nam and the Philippines as the basis for its “international cooperation.” However, these actions appear very unlikely to cover the estimated $4.4 - $5.0 billion cost of offshore mitigation that New Zealand would need to meet the projected abatement gap.
Given these "significant costs," the obvious question is: what has the Government actually done beyond "exploring options for international cooperation"? Has any money been appropriated to purchase offshore mitigation? Treasury's answer, in the 2026 Budget documents, is telling: the Government "has not communicated a sufficiently specified plan to purchase offshore mitigation…to create a valid expectation…that it will do so." In other words, on Treasury's own assessment, there is presently no credible plan to close the gap by either domestic action or international cooperation.
The Government itself has also made its intention clear: last year, the Minister of Finance stated that New Zealand would not be sending “billions of dollars” offshore, and last week, the Prime Minister stated that “...we ain’t shutting down farms and we certainly aren’t sending billions of dollars offshore.”
Therefore, the choice that is being presented, of domestic actions versus offshore mitigation, is not the choice that the Government has been making. Instead, they appear to be pursuing neither.
Why does this matter?
Under Article 4 of the Paris Agreement, parties must pursue domestic mitigation measures with the aim of achieving the objectives of those contributions. As clarified by the International Court of Justice last year, this obligation is one of conduct, requiring a stringent due diligence standard.
In our view, ruling out material offshore mitigation while simultaneously dismantling domestic policy, without any credible alternative plan to close the gap, is not consistent with our international obligations. The consequences of falling short are no longer purely reputational, including:
Trade implications: The EU–NZ Free Trade Agreement includes provisions linking the effective implementation of the Paris Agreement to trade access. A material failure to implement the Paris Agreement exposes New Zealand exporters to the prospect of trade measures (find out more about our trade obligations here).
Inter-state legal exposure: In its July 2025 Advisory Opinion, the International Court of Justice confirmed that breaches of international climate obligations can give rise to state responsibility, including the prospect of inter-state proceedings. That is no longer a theoretical risk.
New Zealand supports 1.5°C-aligned frameworks - but not at home
It has also been reported that states, including New Zealand, “stressed 1.5°C-aligned frameworks”. We welcome these statements from New Zealand. The difficulty is that they sit directly at odds with the Government's recent domestic decisions. For example, late last year the Government passed an amendment under urgency substantially weakening the methane component of New Zealand’s legislated 2050 target: reducing it from 24–47% to 14–24% below 2017 levels.
This was despite officials’ warning the Government that weakening the 2050 target “may be seen as inconsistent” with the 1.5°C temperature goal under the Paris Agreement, as it’s built on a scenario of 2.0-2.7°C warming, and that 14% was consistent only with stabilising methane warming under global mid-range (2.0–2.7°C) and high global temperature increase scenarios (temperature increase well over 2.0°C, and as high as approximately 4.5°C). Minister Watts subsequently recognised this in the media, stating that:
“...the advice we received from the independent science panel in regards to the methane work signals that the 24 per cent target is aligned with 1.5°C… and the 14 per cent is not, no”.
This is particularly important given both methane's dominant role in New Zealand’s overall emissions (including a significant warming effect, with biogenic methane emissions responsible for 66 per cent of New Zealand’s present-day contribution to warming from gross emissions as at November 2024), and the International Court of Justice’s confirmation that 1.5°C is the primary temperature goal of the Paris Agreement.
International negotiations turn on trust that what a country says reflects what it is doing at home. The gap between New Zealand's Bonn statements and its domestic policy settings and Government decisions gives New Zealand a ‘green halo’ that just isn’t the case when the hood is lifted.
Written by Molly McDouall, Solicitor, Lawyers for Climate Action.