The European Union’s energy strategy vows to strive for a fair transition where no one is left behind. Hard-to-reach energy users encompass residential and non-residential groups generally neglected by energy policies. National Energy and Climate Plans (NECP) for 2030 are a key instrument currently being updated by the Member States. In this context, we aim to put the commitment to a just transition to the test by applying a hard-to-reach energy users framework to the draft updated NECPs of Belgium and Portugal. While vulnerable households are mentioned in the plans and tailored and targeted measures are proposed, specific profiles such as rural households, migrants, people with ill-health, and other marginalized groups seem to be overlooked, particularly in the Portuguese case. The need to address excessive energy consumption of high-income households has been the focus of recent research. Still, Belgium’s NECP scantily mentions this group, which is absent in Portugal’s NECP. Specific schemes for the renovation of rented homes are presented in both NECPs but with a much greater level of detail in Belgium’s one. Small and medium enterprises represent most businesses and are mentioned in the NECPs, while a much smaller focus is given to micro-enterprises. Commercial subsectors seem to be adequately mentioned, although activities such as food services do not attract much attention. We conclude by arguing that, even if some promising examples can be found, policymakers can do more to ensure the engagement of hard-to-reach groups in the energy transition.