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Follow the Input: What the New EU Arctic Strategy Did With the Public Consultation 

EUs høyrepresentant for utenriks- og sikkerhetspolitikk Kaja Kallas, og Norges utenriksminister Espen Barth Eide under konferansen Arctic Frontiers i Tromsø.
EU High Representative for Foreign Affairs and Security Policy Kaja Kallas and Norwegian Minister of Foreign Affairs Espen Barth Eide during the Arctic Frontiers conference in Tromsø.
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This is an op-ed written by an external contributor. All views expressed are the writer's own.

 On the 20th of October 2026, the European Commission and the High Representative for Foreign Affairs launched an update to its Arctic policy, now entitled: Europe's Northern Neighbourhood: A New Strategy for the Arctic. In an interview with Ritzau published two days later, a journalist asked Commissioner Jozef Síkela, responsible for international partnerships, a simple question:

Was the strategy’s strong focus on security and dual-use infrastructure driven by the wishes of the EU and NATO, rather than by the people who live in the Arctic? The security dimension, he replied, was “driven by geopolitical change”. Yet the strategy describes itself as “shaped together with our Arctic partners and the people who call the Arctic home”. 

The new strategy is a revised version of the 2021 Joint Communication on the Arctic and – among others – follows two inputs. In November 2025, the European Parliament adopted a recommendation on the EU´s diplomatic strategy and geopolitical cooperation in the Arctic. A month later, the Commission opened a public consultation on its Have your say portal, which ran from December 2025 to March 2026.

It drew about 1,640 submissions, more than any previous EU Arctic policy consultation. In August, we presented analysis of this public consultation and found two clusters of near-identical texts that accounted for roughly 525 entries, possibly 40 percent of citizen submissions, against the 61 ‘campaign’ contributions identified on the Commission's own site.

The single largest theme, a halt to new Arctic oil and gas, was also the most coordinated. In general, citizens wrote about the environment; institutions wrote about security, cooperation and the EU's role. Nordic citizens, the people most exposed to a changing Arctic, made limited contributions.

The largest theme, “a halt to new Arctic oil and gas”, was only partially addressed

We warned that if the process meant to legitimise a more security-oriented policy could not represent the voices of those most affected, the policy would inherit the same legitimacy gap. So, what became of the four dominant themes identified in the submissions? 

What happened to the themes 

The largest theme, “a halt to new Arctic oil and gas”, was only partially addressed. As Sixty-two percent of submissions asked the EU to stop new Arctic oil and gas exploration. The new strategy restates the EU’s general position that oil, coal and gas should “stay in the ground, including in Arctic regions”, and claims to do so “in line with the 2021 Joint Communication”.

Like the Parliament’s 2025 recommendation, it drops the 2021 pledge to work towards a multilateral legal obligation not to allow further hydrocarbon development, nor to buy what is produced there. The passage has also moved from the climate chapter to the economy chapter, where it now sits under renewable energy. 

At the launch briefing, a senior official told reporters the EU “will not drill in the Arctic, and we will not buy hydrocarbons from the Arctic.” This commitment exists only in that briefing room.

The text itself only commits the Commission to “work with partners to protect the Arctic environment and prevent all hydrocarbon reserve developments that pose a threat to the Arctic ecosystem”, which suggests a case-by-case approach.

That falls well short of the 2021 Joint Communication’s aim to “work with partners towards a multilateral legal obligation not to allow any further hydrocarbon reserve development in the Arctic, or contiguous regions, nor to purchase such hydrocarbons if they were to be produced”. Either way, an important reminder here is that most Arctic oil and gas resources lie in Norway, Alaska and Russia, hence outside the EU. 

The second theme, “protecting Arctic biodiversity, fisheries, habitats and species”, was answered with existing tools, updated with the most recent developments. Fifteen percent of submissions, mostly from individual citizens and environmental groups, asked for the protection of ecosystems and action on pollution.

The new strategy’s climate chapter builds on the BBNJ Agreement and OSPAR marine protected areas and adds the 2024 Nature Restoration Regulation and the Birds and Habitats Directives. All of this existed before the consultation; the strategy simply makes it explicit.

It also pushes harder at the IMO for binding black carbon rules, already an aim in 2021, and for defining “wider Arctic waters” as everything north of 60°N. 

The third theme, “a precautionary pause on new industrial uses” in the Arctic, has a mixed outcome. Eight percent of respondents asked for such a pause until safeguards and governance were stronger. The precautionary approach survives for geo-engineering, deep-sea mining and fisheries in the Central Arctic Ocean, but on shipping the strategy points the other way.

More Arctic shipping “substantially escalates the risk of catastrophic accidents”

The 2021 Joint Communication treated Arctic shipping mainly as a source of pollution and a safety problem, and gave ports only one sentence. The 2026 strategy, by contrast, wants to “unlock the growing potential of Arctic maritime flows” by tying European ports, rail and energy terminals into emerging Arctic trade and transport networks, and commissions a foresight study on emerging corridors.

It does so while warning, in its own security chapter, that more Arctic shipping “substantially escalates the risk of catastrophic accidents”. Tellingly, the Norwegian Ministry of Foreign Affairs input to the Parliament’s 2025 recommendation warned of "much hype" about the Northeast Passage and called for a “realistic description” of its potential as a shipping route between Europe and Asia. 

The fourth, and smallest, theme, “Security, Cooperation and the role of EU leadership”, became the main priority. Six percent of submissions concerned this theme, mostly from institutions rather than citizens. Security is the first thematic chapter of the new strategy, after the Northern Neighbourhood framework, and the logic that holds the rest together:

Climate change is a “risk multiplier”, climate resilience “a precondition for security”, ports and railways are dual-use, and the Arctic, the North Atlantic and the Baltic are “a single and interconnected strategic space”. By one count, the word “security” appears 52 times in the 2026 text, against 46 times in the Parliament’s 2025 recommendation and only 23 in the 2021 Joint Communication.

“Defence” went from 1 mention in 2021 to 10 in 2025 and 17 in 2026. Meanwhile, “climate change” fell from 30 mentions in 2021 to 14 in 2026, and words built on “sustainab-” dropped from 44 in 2021 to 17 in 2025, before recovering to 37 in 2026. 

None of this is necessarily wrong. We argued in August that a louder consultation is not a more representative one, and that treating 1,640 submissions as a single verdict flattens two very different conversations. The security shift was asked for by the European Parliament in November 2025, by twelve member states, in Rovaniemi, in September 2026, and by the European Council days before the launch.

The Commission had to reconcile contradictory voices. The problem is that it has not said how it did so. The word “consultation” does not appear once in the strategy. 

What feedback loop? 

On the 22nd of April 2026, the Commission published a “factual summary of the public consultation”. The 22-page document covers only 177 replies to an online questionnaire that was far less publicised than the Have your say portal. Respondents included 106 EU citizens, 20 public authorities, 14 research institutions, 14 NGOs, 7 businesses, 8 non-EU citizens, and 8 others. It does not address the roughly 1,640 submissions the Commission received, which we analysed in our previous piece.

Its header even refers to a “public consultation on migration”, an apparent copy-paste error that remains uncorrected. Still, even within those 177 replies, a ban on new oil and gas appears in almost every thematic block, and about half of respondents “highlighted the need for the EU to strengthen international cooperation and diplomacy in the Arctic, including by reestablishing dialogue with Russia and promoting peaceful conflict resolution”.

The strategy goes the other way: multilateral cooperation “can no longer be the sole foundation” of the EU’s Arctic policy, partnerships with “like-minded” countries take priority, and “peace through strength” is the new focus. On shipping, a majority of respondents showed limited support for Arctic shipping routes, even considering recent geopolitical tensions. 

Everybody claims victory 

A month before the launch of the new strategy, the International Federation for Human Rights announced that the EU would keep its drilling ban, thanks to “an unprecedented civil society mobilisation that saw over 1,600 submissions.”

On launch day, NRK reported that, in the opinion of Norway’s energy minister, the EU had “more or less accommodated Norway's view”, and that both the oil industry and WWF Norway welcomed the text. 

They welcomed the Youth Sounding Board in Nuuk and the recognition of their priorities.

These four readings concern the EU’s position on Arctic oil and gas, and they cannot all be right. They are possible because the Commission has not said what it did with any of any of their submissions. Each participant reads its own submission into the text and declares success. 

One group asked a relevant question. Two days after the launch, young people from the Arctic Youth Dialogue, which has delivered recommendations to the EU in 2024, 2025 and 2026, published a response through the Saami Council. They welcomed the Youth Sounding Board in Nuuk and the recognition of their priorities.

Then they asked the EU to “show how their recommendations between 2024-2026 inform decision-making with transparent follow-up”, and for participation “from agenda-setting to implementation, not consultation alone.” That is the standard the consultation failed to meet.

The strategy’s own engagement section promises communication to “demonstrate the added value” of EU action, not an account of what became of people’s input. Perhaps Brussels judged that a price worth paying. But a strategy in which everyone can claim victory is at risk of being one nobody can hold to account.

The authors have used AI as an aid to parts of the text.

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