Climate protection now! WWF is pushing for sensible investments in special funds

Climate protection now! WWF is pushing for sensible investments in special funds

On June 23, 2025, the WWF published a clear demand: Climate protection must play a central role in investment decisions for the special fund. This demand is supported by new legal analyzes from the Günther law firm, which were prepared on behalf of the WWF. The special fund, which has a total of 500 billion euros, will primarily be used to finance climate protection measures. The planned funds for the Climate and Transformation Fund (KTF) amount to 100 billion euros. The WWF also demands that climate protection be viewed as an equal goal alongside infrastructure investments.

Viviane Raddatz, head of climate at WWF Germany, emphasizes that the special fund offers a unique opportunity to finance the new federal government's climate protection program. However, the current draft bill shows that 300 billion euros for infrastructure investments do not meet the WWF's requirements. It is necessary that the establishing law contains clear definitions for investments and their additionality in order to ensure legal certainty.

Legal basis and requirements

According to the WWF, the Basic Law requires timely investments in climate protection. The money should not flow into measures that hinder climate protection, especially not into fossil infrastructure. Another concern is that natural climate protection measures are also included in the definition of investments. In order to review the implementation of the special fund, an effective governance structure is required, which also includes reporting and monitoring obligations.

In addition to the profitability controls, an investment climate check is to be introduced. The relief from fossil energy prices is not part of the KTF law, which clearly advocates investments in climate protection, energy transition and sustainable transformation. Financing fossil fuel measures should only be possible through budget funds or national CO2 pricing and not through European emissions trading.

Financing and use of the special fund

The special fund is now supported by an amendment to the Basic Law, which the Federal Council has already approved. These changes limit the debt brake, so that certain expenses such as defense or civil and civil protection will not be counted towards the debt brake in the future. The new special fund for infrastructure and climate neutrality has a term of 12 years, and it is expected that the specific uses of the funds will be determined in the next few months.

Of the 500 billion euros in the special fund, 100 billion euros are earmarked for the federal states. These funds are intended to help expand heating and energy networks in particular. However, it is necessary that the investments are additional, which means that the share in the federal budget must exceed 10% of the total expenditure without special funds.

Deutsche Bahn has already announced a need for 148 billion euros from the special fund, with a total investment requirement of 290 billion euros by 2034. There is also a high need for financing in the areas of transport infrastructure, healthcare and education. It remains to be seen how the future federal government will determine the specific use of funds. Private companies can also participate in the special fund through public contracts and funding programs and thus contribute to the implementation of investments.

The WWF's requirements for an effective special fund illustrate the need for a sustainable approach in order not to lose sight of the federal government's climate goals. A shared responsibility is required to set the course for a sustainable and climate-neutral society.

For further information, see the full WWF press release here and the analysis of Taylor Wessing here available.