Global Momentum for Transparency? A new Initiative for the Enhanced Transparency Framework

This year has been an unusual year. While the Covid-19 pandemic has forced countries around the globe into lock-downs and led to a major economic downturn, 2020 was meant to be the year for crucial global climate action. Countries that are Parties to the 2015 Paris Agreement were supposed to communicate new or updated Nationally Determined Contributions (NDCs), put forward long-term low emission development strategies, and reach an agreement on the modalities of future carbon markets, at the 26th Conference of the Parties (COP) in Glasgow, originally scheduled for December 2020. However, as the global community is coping with a second wave of Covid-19, only twenty-two countries, representing 8.6% of global emissions, have submitted an updated or second NDC (ClimateWatch 2020) and COP 26 has been postponed to 2021. Instead, the United Nations Framework Convention in Climate Change (UNFCCC) organized virtual “Climate Dialogues” from 23 November to 4 December 2020, to advance work under its subsidiary bodies and the COP agenda as well as to showcase progress made in 2020.

In the opening ceremony for the Climate Dialogues, UNFCCC Executive Secretary Patricia Espinosa launched a new initiative called the “Initiative of Universal Participation in the Enhanced Transparency Framework (ETF)”. What is striking here is the word universal. The Enhanced Transparency Framework calls for countries to report on their greenhouse gas emissions and national climate actions as laid out in Article 13 of the Paris Agreement. In contrast to earlier UNFCCC rules, the ETF applies to all countries and thus abolishes former differentiation between Annex I (developed) and non-Annex I (developing) countries in transparency-related obligations. Yet it also provides for flexibilities in reporting from developing countries, and grants least developed countries and small island developing states discretion regarding when to report. In fact, Article 13 does not mention universal or universal participation, nor do the 41 pages of its implementation guidelines (called modalities, procedures and guidelines). So, what is meant by universal participation?

All hands on deck for transparency?

As the UNFCCC Secretariat sees it, the objective of this new transparency initiative is to “bring together countries, support organizations, the business community, non-governmental organizations and other stakeholders to realize the benefits of the strengthened transparency requirements under the Paris Agreement’s enhanced transparency framework (ETF)” (UNFCCC, 2020a). Further, it is stated here that “for the Paris Agreement to deliver on its objectives, universal participation in the ETF is required”. Thus, this initiative aims to bring “all actors together under a common banner”.

This ‘all- hands-on-deck’ thinking is usually only used in the context of actual climate actions by non-state actors such as businesses, cities and regions, to signify the importance of everyone acting to address climate change. Applying this thinking to transparency is novel, at least in the context of reporting under the UNFCCC, which is and always has been a requirement applicable to states. While many businesses, investors and cities around the globe do report on their greenhouse gas emissions and reductions, through various portals such as the CDP (formerly known as the Carbon Disclosure Project), the C40 city network and the Covenant of Mayors, the integration of this data into national GHG inventories is difficult due to issues such as additionality and double-counting of emissions.

Momentum for transparency or momentum for climate action?

One of the new initiative’s main goals is “to generate global momentum towards enhancing the understanding of the importance and benefits of transparent climate-relevant data and information for the implementation of the Paris Agreement”. Yet one might wonder whether it is really global momentum for transparency that is needed or rather global momentum for ambitious climate action and support for climate action. As the recent UNEP Emissions Gap Report found, current Nationally Determined Contributions (NDCs) by Parties of the Paris Agreement “remain seriously inadequate to achieve the climate goals of the Paris Agreement and would lead to a temperature increase of at least 3oC by the end of the century” (UNEP, 2020).

The initiative’s focus on data and information as a pre-condition for climate action and implementation is very much aligned with the ETF itself, which aims “to build mutual trust and confidence and to promote effective implementation” of the Paris Agreement (UNFCCC, 2015, emphasis added). But countries have already been reporting on their greenhouse gas emissions and their mitigation and other climate actions for years, in the context of Biennial Reports and Biennial Update Reports. As such, one would assume that they would be aware of the much vaunted “importance and benefits of transparent climate-relevant data and information”. However, the latest NDCs that countries have submitted are not sufficient to get the world on track towards the temperature goals in the Paris Agreement. This discrepancy between the rhetoric around transparency and the reality of non-ambitious action is striking. It demonstrates that data and information are not a panacea, and that the process of using information for effective policy-making is far from straight-forward. Under the ETF, countries are required to track their own progress in meeting their NDCs through indicators, but obligations around tracking an NDC will not make up for an unambitious NDC. Furthermore, a large majority of NDCs from developing countries are conditional on financial support from developed countries, another political axis of conflict in the multilateral climate policy context that is tied up in complex ways with reporting obligations.

The same positive view on the potential of data and information has been included in another goal of this new, ‘universal ETF’ initiative, namely to “increase political awareness and buy-in at the highest national level for an evidence-based national decision-making process with a broad base of stakeholder engagement”. But national decision-making processes are political processes with many competing agendas and are rarely based solely on scientific data. Furthermore, a broad base of stakeholder engagement and high-political buy-in are more relevant in the context of taking actual climate action, rather than the transparency thereof.

Welcome initiative or duplication of efforts?

Other goals of this new initiative include to “mobilize support needed for building up and strengthening domestic capacities for Parties and other stakeholders, including robust and sustainable institutional arrangements for climate-relevant data” and “facilitate enhanced access to support to developing country Parties by offering a platform for wider stakeholder engagement, including North-South and South-South cooperation”. However, there are already various initiatives in place to support developing countries in enhancing their institutional and technical capacities, most notably the “Capacity-building Initiative for Transparency (CBIT)”. The CBIT was established at COP 21 in Paris, and as of November 2020, more than 60 countries are preparing or implementing CBIT projects. As originally stated in the CBIT Programming Directions, the goal of this initiative is to support a minimum of 100 countries “that have articulated their capacity needs and priorities for transparency” (GEF, 2016, p. 8). However, future funding of the CBIT is uncertain and most of its resources have already been programmed. As such, if there is indeed interest in supporting developing countries to be more transparent, mobilizing support for continuing the CBIT would be more sensible.

Another prominent effort is the “Initiative for Climate Action Transparency (ICAT)”, established by the Ministries of Environment of Germany and Italy, the ClimateWorks and the Children’s Investment Fund Foundations. ICAT supports 40 countries in enhancing their transparency capacities, a number of which are also supported by CBIT. However, ICAT is set to end next year unless it is prolonged and receives additional funding. Other transparency support efforts targeted at developing countries include the “Consultative Group of Experts” under the UNFCCC, the “Partnership for Transparency in the Paris Agreement” and the “Global Support Programme for National Communications for National Communications and Biennial Update Reports”. The latter initiative will merge with the CBIT Global Coordination Platform into a Global Transparency Platform. Other prominent initiatives also have transparency elements, such as the NDC Partnership. Furthermore, the UNFCCC also supports countries in transparency-related matters through its Regional Collaboration Centers. With all of these different initiatives, projects and efforts to strengthen countries’ transparency capacities already in place, one wonders whether another transparency initiative will add value to the existing ones, and if and how these can be meaningfully integrated without duplicating efforts. Strikingly, the scarce information currently available on this new transparency initiative does not mention the others, not even the CBIT.

In the context of mobilizing support for developing countries to become more transparent, the initiative intends, furthermore, to provide a platform “to tailor the support to [developing countries] needs”. It will be interesting to see how this tailored support will take shape, and if and how it will differ from other support currently provided. Particularly important is how the needs of developing countries will be elicited and whether these needs will only cover mandatory reporting elements (GHG inventory and NDC tracking) of the ETF. The actual (transparency) needs of a country might differ from these mandatory reporting elements (e.g., countries might wish to prioritize reporting on adaptation, for example).

The announcement relating to this new initiative states in addition that it is “open to all interested stakeholders” including Parties, international organizations and non-state actors such as NGOs and businesses. Facilitating exchange and consolidating the interests, needs and inputs of these wide-ranging stakeholder groups under one initiative will, without doubt, be challenging. A similar approach has been attempted by the “Paris Committee on Capacity-building (PCCB)” which established a network in the Spring of 2020. This network is open to any stakeholder in the space of climate and capacity, and already has 216 member organizations, ranging from NGOs to research institutions to UN agencies.  This PCCB is to “become a leveraging platform to enhance coherence and coordination of climate-related capacity-building initiatives and activities” (UNFCCC 2020b, emphasis added). One can imagine that the new transparency initiative will become a similar kind of ‘leveraging platform’.

Interestingly, the PCCB itself and its network also conduct transparency activities. The PCCB meeting in June 2020 for instance focused on transparency and a number of the PCCB Network members work on climate transparency, such as the Greenhouse Gas Management Institute and the Global Support Programme. Thus, here too, could potentially be overlap with the new transparency initiative. Whether this new transparency initiative will become as large as the PCCB network remains to be seen but there is a risk of overcrowding, making it difficult to achieve meaningful results. As such, the initiative should also outline its expected results and clearly define indicators to measure its progress to not risk becoming an “empty shell”.

Problematizing the Turn to Ever More Transparency

This initiative was established in support of the ETF and is thus inevitably optimistic of the potential for transparency to foster greater accountability, mutual trust, climate action and ambition. The initiative reiterates this optimism by stating that “stakeholders can learn from each other and build mutual trust and confidence that will unleash long-term transformational development and ambitious climate action”. However, the link between transparency and enhanced trust or between transparency and enhanced climate ambition are far from evident, and remain to be studied. The TRANSGOV project will examine precisely these links in assessing, systematically and empirically and for the first time, the transformative potential of transparency in global climate governance. It will address the question: can and does transparency actually help to realize these prescribed effects?

Very little information is yet available about this latest transparency-related UNFCCC initiative. It is important, given the ever-growing attention that transparency is now receiving, to learn more about how it came about in the first place. Were Parties to the Paris Agreement asking for this specifically? With so many other initiatives and efforts in place that focus on transparency, even within the UNFCCC itself, one cannot help but wonder whether the global community needs another transparency initiative, and one that again shines a light on facilitating developing country transparency. This is especially questionable in light of a recent report by the OECD (2020), which finds that USD 78.9 billion of climate finance were provided and mobilized in 2018, which is still a long way to go to achieving the goal of USD 100 billion climate finance annually starting in 2020. Yet, even reaching the goal of USD 100 billion will be far from sufficient to implement the conditional elements of developing countries’ NDCs. At the same time, it is strongly contested how the USD 100 billion are actually counted (see Weikmans, Roberts & Robinson, 2020).

Equally worrying are the results of the recent “Production Gap Report” by the Stockholm Environment Institute and others, which show that governments have committed far more Covid-19 recovery funds to fossil fuels than to clean energy (SEI, IISD, ODI, E3G & UNEP, 2020). So why is so much support and attention being given to transparency of action rather than to action itself, especially action from Annex I countries, and especially in the midst and coming aftermath of a global pandemic where climate action might not be prioritized in countries?

In sum, while all new initiatives and efforts that keep climate change on the global agenda are to be lauded, the ever-growing focus on enhancing transparency of countries’ greenhouse gas emissions and national actions can risk becoming a distraction from the “the elephant in the room”, namely the taking of climate actions by all, and the need for support for climate actions being taken by developing countries. A number of scholars have already pointed out this potential for distraction-through-transparency, notably Gupta and van Asselt (2019) and Klinsky and Gupta (2019). This and further assumptions related to the role of climate transparency in global climate governance will be examined in the four-year TRANSGOV project.

Read more about the different research themes of TRANSGOV here.


ClimateWatch (2020). 2020 NDC Tracker (website). Available at:

GEF (2016). Programming Directions for the Capacity-building Initiative for Transparency. Available at:

OECD (2020). Climate Finance Provided and Mobilised by Developed Countries in 2013-18. Available at:

SEI, IISD, ODI, E3G & UNEP (2020). The Production Gap (website). Available at

UNEP (2020). Emissions Gap Report 2020. Available at:

UNFCCC (2015). Paris Agreement. Available at:

UNFCCC (2020a). Initiative of Universal Participation in the ETF (website). Available at:

UNFCCC (2020b). Launch of the PCCB Network (website). Available at:

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