The conservation of wild species of animals and plants in the European Union (EU) is embedded in a wider international normative framework, and a deteriorating trend with regards to biodiversity has been identified for the past as well as for the future (EEA 2025). The objective of this Comment is to outline how the EU in 2025 downgraded the conservation of critical populations of the wolf (Canis lupus) within its multilevel geopolitical system, the main counterarguments and ongoing mitigation initiatives.

The EU is, on the one hand, party to international biodiversity agreements and, consequently, enacts related strategies of its own (CBD 2025, CMS 2025, EU 2020). On the other hand, an EU Council Decision (EU 2024) in September 2024 initiated a downgrading of the wolf based on an unquoted European Commission (EC) proposal and on the reasoning of a single report by the Large Carnivore Initiative for Europe (Boitani et al. Reference Boitani, Kaczensky, Alvares, Andrén, Balys and Blanco2022), as well as an unspecified ‘in-depth analysis of the status of the wolf in the Union from 2023’ (EU 2024, recital 8 of preamble; but see EC & N2K Group 2023, European Ombudsman 2024). This conservation downgrading was subsequently introduced into the international Bern Convention (Council of Europe 2024) mainly due to the EU’s voting power, and, finally, in June 2025, into an amendment of the EU Habitats Directive (EU 2025). The amended Directive, for example, no longer requires any EU Member States to introduce a system of strict prohibitions on the hunting, capture and degradation of breeding sites (with limited derogation opportunities), nor a system to monitor the incidental capture and killing of wolves (and to set counteractions in such a case; EU 1992, articles 12 and 14). This happened though even the reasoning report (Boitani et al. Reference Boitani, Kaczensky, Alvares, Andrén, Balys and Blanco2022) concludes by criticizing a variety of the current monitoring approaches on the basis of the fragmentation of management authorities, identifying several near-threatened and vulnerable populations of the wolf and outlining at least four emerging threats facing this emblematic species.

The EU’s amendment to the Habitats Directive could not have been passed without the earlier Council Decision paving the way for the EU to insist on downgrading the wolf’s status under the Bern Convention. The way that the Council Decision (EU 2024) is formulated, particularly by not publicly stating in a transparent and traceable way its scientific basis, reflects existing criticism of the EU’s administrative actions from the so-called Aarhus Convention Compliance Committee (ACCC 2025) and is therefore also procedurally questionable as regards transparency and comprehensiveness. The EU also apparently refrained from sufficiently promoting public participation in these international Bern Convention procedures, potentially contradicting Article 3(7) of the Aarhus Convention (AC). As far as can be discerned, this Article has, to date, never been mentioned in the findings of the ACCC (ACCC 2025), but in the literature its potential is recognized (Epiney et al. Reference Epiney, Diezig, Pirker and Reitemeyer2018, p. 128). The lack of transparency and scientific rigour in forcing the downgrade in protected status of such a species erodes the global credibility and legitimacy of the EU as a frontrunner in biodiversity conservation. Nongovernmental organizations (NGOs) have appealed to the Court of Justice of the European Union (CJEU) against this Council Decision also based on the lack of scientific rigour and further reasoning, other than that based on the AC (CJEU 2025a, 2025b). In the light of the questionable aspects in this Decision related to the AC outlined here, NGOs can assess the extent to which the AC-related arguments need to be or can still be included in the ongoing CJEU procedures, or the extent to which they can propose new ones. In addition, a complaint to the ACCC regarding the EU as party to the AC potentially infringing its obligations can be taken into consideration by NGOs.