Will anybody dare resuscitating the EU ETS?

As the European Commission prepares an integrated framework on climate resilience and risk management for the EU, the public consultation has just wrapped up – an important step towards the publication of the proposals for the framework later this year. One of the main areas of focus will be the issue of financing adaptation, with the first key challenge being to mainstream the concept of resilience by design into all European funding currently under discussion, including structural policies such as the Common Agricultural Policy and the Connecting Europe Facility.

Adaptation needs in emerging markets and developing economies (EMDEs) are rising rapidly, yet current financing assessments systematically underestimate the scale of the challenge. This paper calls for a shift from headline finance targets towards strategies that fully integrate cost of capital considerations, combining concessional finance, revenue mobilisation, and structural reforms to unlock durable and scalable investment in climate adaptation in EMDEs.

This report, originally published in French in September 2025, is a contribution to the public debate on adaptation in France. The methodologies applied, the data collection process, as well as the analytical framework proposed, may inform broader discussions in Europe, as the preparations for an EU integrated framework for European climate resilience and risk management are well underway.