FROM JUDGMENT TO COMPLIANCE: EXECUTING CLIMATE-RELATED JUDGMENTS UNDER ARTICLE 46 ECHR

Climate-related judgments of the European Court of Human Rights require measures that are long-term, structurally complex, science-dependent and continuously evolving. Yet the scholarship triggered by the Court's first climate judgment has concentrated on the merits, while the machinery that must give those judgments effect has attracted far less doctrinal attention. This article asks how adequate the Article 46 execution system is for supervising compliance with judgments whose implementation extends over decades. Drawing on the verified supervision record of Verein KlimaSeniorinnen Schweiz v Switzerland before the Committee of Ministers between 2024 and 2026, and on the execution history of Italian environmental judgments, it examines whether the existing architecture, built around static assessment of action plans and reports, can distinguish formal from procedural, substantive and evidence-based compliance. The article reconstructs the Committee's March and September 2025 decisions, the intensive Rule 9 practice that shaped them, and the Committee's decision to delegate monitoring to a national climate body rather than to adjudicate the science. On that basis it proposes a framework of dynamic compliance, under which supervision is organised around iterative review cycles, measurable indicators and structured third-party participation, and it assesses what the Inter-American follow-up model and national climate advisory bodies suggest about how such a framework could work. The argument is not that Article 46 is failing; the record shows a system under strain that is already improvising. The contribution is conceptual and institutional: it identifies what climate judgments change in the logic of execution supervision, where the current model falls short, and what a defensible adaptation, respecting the Committee's political character and the State's margin of appreciation, would require.