To effectively address the root causes of carbon lock-in across developing countries, Nationally Appropriate Mitigation Actions (NAMAs) with transformational change characteristics are being supported by donors and finance mechanisms as a means to achieve ambitious nationally determined contributions (NDCs). However, there is still a scarcity of empirical studies on how transformational change policies and actions are designed and supported in practice. This article addresses such a gap in knowledge by combining theoretical insights from the multi-level perspective and transitions management literature to examine a donor-supported cement sector NAMA in Tunisia developed during 2012–2013. A narrative is constructed to analyse the adequacy of the NAMA design to promote structural shifts towards low carbon development in the cement sector. Data collection is based on semi-structured interviews and documentation gathered during field work in Tunisia 2014–2015. The study finds that the NAMA design is not likely to lead to transformational change of the cement sector, since underlying factors accounting for lock-in are not properly tackled. Although the NAMA has enabled new and promising sectoral partnerships across the cement sector, the analysis suggests that the NAMA’s transformational potential is currently limited by a number of factors not being adequately addressed. Measures are proposed to reorient the NAMA towards promoting system innovation, building on further research and experimentation with the policy entrepreneurial role of donors.