Key Highlights:
- By the end of this year all countries have to submit their first biennial transparency reports under the Paris Agreement. COP29 will push for all countries to meet this deadline. However, this is a challenging goal to meet for many developing countries. The risk is that reporting becomes a ‘tick box’ exercise where countries with less capacity stand to lose.
- Developing countries have repeatedly stress the need to re-configure international support for reporting. They will continue to do so at COP29. With mandatory biennial reporting, developing countries stress the need to build local capacities. But support rules under the Global Environmental Facility of the World Bank are not easily amended.
- Reporting on adaptation and loss and damage have historically received less attention than reporting on emissions and mitigation. Various processes are underway to generate more guidance on reporting on these crucial matters. It remains to be seen how adaptation and loss and damage will feature in the first biennial transparency reports.
- Developed countries will be under scrutiny at COP29. A UNFCCC Secretariat synthesis report contains politically salient information on developed countries’ mitigation and climate finance performance. COP29 will consider this report, and potentially turn transparency into action.
2024 is an important year for transparency in the international climate regime. By the end of the year, the first biennial transparency reports (BTRs) are due under the Paris Agreement’s new enhanced transparency framework. At COP29 there will be much buzz around these new transparency reports. But there are also other important transparency matters on the agenda which may attract less limelight but are equally crucial. This blogpost discusses four crucial issues related to the politics of transparency at COP29 that will have implications for how transparency continues to evolve under the international climate regime.
All Eyes on the BTRs: Who Gets the Fame (and Who Gets the Blame)?
Under the enhanced transparency framework of the Paris Agreement, countries are to submit their first biennial transparency reports (BTRs) by the end of this year.[1] At the time of writing, four countries have submitted their first biennial transparency report: Andorra, Guyana, Japan and Panama.[2] COP29 will set the tone for how the submission or non-submission of biennial transparency reports before the deadline will be dealt with in the international climate regime.
Early submitters of biennial transparency reports can expect to be celebrated. Indeed, the President-Designate of COP29 wrote a letter to Parties, highlighting the importance of transparency and encouraging countries to submit their first biennial transparency reports in advance of COP29. Those who have done so will get special limelight. For example, there will be a side-event organized by the UNFCCC Secretariat dedicated to Guyana’s transparency report and its experience with the technical review process of this report.[3] The Executive Secretary of the UNFCCC also had special praise for Andorra and Guyana for being the first to submit a biennial transparency report, and he encouraged all countries to submit a report by the end of this year.
To add further momentum, the COP29 presidency has also hosted, earlier this year, a High-Level Dialogue on Climate Transparency in Baku, and a High-level Dialogue on Global Climate Transparency during the 79th session of the UN General Assembly. These efforts are to culminate in the establishment of the Baku Global Climate Transparency Platform and the adoption of a Transparency Declaration at COP29, both of which are to provide a further push to ensuring as many countries as possible submit their first biennial transparency report as soon as possible.
Yet where there is fame for the early submitters, there is also potential blame for those who do not manage to submit their first biennial transparency report before the end of the year. To some this might seem justified. After all, it is a multilaterally agreed rule to submit these reports. But the question is: are we celebrating or blaming countries based on the right metric? If a country is good at reporting, that is great, but it does not necessarily mean the country is also a climate champion. On the other hand, countries that are late in submitting reports might still be among those with very low emissions.[4] In other words, it should be the content of the report (relating to the climate actions undertaken in the country) that should be determining who is celebrated and who is not, rather than simply ticking the box of submitting the report.
A further problematic element of using submissions of biennial transparency reports to celebrate or blame countries, is that it is likely that all or most developed countries will manage to submit their reports by the deadline while many developing countries will struggle to do so. This is to be expected because the enhanced transparency framework basically requires developing countries to ‘catch up’ to the level of reporting previously applicable to developed countries under pre-Paris rules, especially on the greenhouse gas inventory and mitigation front.[5] In other words, it is a tilted playing field in terms of countries’ readiness to be submitting these new reports. And while there are various support initiatives to help developing countries prepare for their biennial report submissions, these also have their shortcomings, as will be discussed below.
Support for Climate Reporting: A Paradigm Shift or More of the Same?
For a number of years, countries have negotiated over whether and how support for reporting under the Paris Agreement needs to be reconfigured. Developing countries argue that support is insufficient to cover all costs. Moreover, developing countries argue that the modalities for support provided by the Global Environmental Facility are not fit-for-purpose. This because of constraints preventing national ministries in developing countries to use Global Environmental Facility funding to establish permanent positions to manage international reporting. Developing countries, with South Africa being particularly vocal on this, argue that the funding infrastructure perpetuates a reliance on external consultants and does not allow for the building of capacity within the government. To address this issue, the Global Environmental Facility would need to reconfigure its rules attached to funding provision. However, developed countries have argued that the UNFCCC is not the space to be doing this, arguing that the board of the World Bank is responsible for negotiating these matters. This stalemate has continued for multiple UNFCCC negotiation sessions.
One important development in the support for reporting landscape is that COP29 will see the launch of the Baku Transparency Platform. It was developing countries who asked last year for a Dubai Transparency Platform to ramp up support for developing countries to implement the enhanced transparency framework. Some countries will be happy with the establishment of the Baku Transparency Platform. For others, this is more of the same: just another venue for training and workshops, without any fundamental rethinking of support mechanisms or how they can be made more programmatic and geared toward building domestic capacities. But if domestic capacities are to be developed for reporting, a further important question is: capacities to report on what? This brings us to another topic to watch at COP29: whether the ever-dominant focus on mitigation-related reporting is slowly making place for reporting on adaptation and loss and damage.
Reporting on Adaptation and Loss and Damage: The Underdogs No More?
Reporting on adaptation and loss and damage has often been in the shadow of reporting on greenhouse gas emissions and mitigation actions. Under the enhanced transparency framework reporting on greenhouse gas inventories and mitigation actions is mandatory whereas reporting on adaptation and loss and damage is voluntary. There is extensive, multilaterally agreed guidance for reporting on greenhouse gas inventories, while reporting guidance for adaptation and loss and damage remains limited. There is also evidence that internationally supported capacity building projects for reporting often focus on mitigation reporting rather than adaptation and loss and damage.[6]
But over the last years, adaptation and loss and damage reporting are catching up, be it from a far distance. At COP27 it was decided that countries could on a voluntary basis submit their adaptation chapters in their biennial transparency reports for technical review, and that they could highlight specific sections (importantly, one of them could be loss and damage) for specific attention. COP28 further included an outcome that requested the Executive Committee of the Warsaw International Mechanism for Loss and Damage to produce further guidance on loss and damage reporting,[7] and it requested the secretariat to draft a synthesis report of loss and damage information in biennial transparency reports. In addition, various non-state actors have stepped in with working papers on how countries might want to go about loss and damage reporting under the enhanced transparency framework.[8]
COP29 might further this trend of lifting the importance of adaptation and loss and damage reporting. A case in point here is the ongoing process of developing indicators to track progress on the global goal on adaptation, set to conclude next year at COP30. However, it is not self-evident that countries will in practice report on adaptation and loss and damage in their first biennial transparency reports, even for developing countries for whom these are important topics. After all, adaptation and loss and damage remain voluntary elements of reporting, and some have argued that countries should first and foremost focus on the mandatory elements of the enhanced transparency framework.[9] It thus remains to be seen if and how adaptation and loss and damage will be reported on in the first round of biennial transparency reports. This will be determined, not in the least, by developing countries’ expectations on what reporting on adaptation and loss and damage might deliver for them. Indeed, whether transparency translates into action is not self-evident, a point to which we turn next.
Submit and Synthesize: Turning Climate Transparency into Action?
In October 2023, the UNFCCC secretariat published a synthesis report of the fifth biennial reports submitted by developed countries under pre-Paris reporting rules. While biennial reports might sound technical and dull, the careful reader of the synthesis report will find pearls of politically salient pieces of information.
First, the synthesis report noted, in paragraph 182, that self-reported projected emissions by developed countries showed that ‘no Party will achieve its targeted level of emissions in 2030 set out in its NDC.’ This is a consequential finding. It means that developed countries must formulate and implement additional climate policies before the end of this decade to meet their targets. While there is still time for developed countries to do so, this finding does merit special attention in the future from the international community in terms of following up on whether developed countries have taken the necessary measures to inch closer towards meeting their 2030 NDC targets. The issue of self-reported projections was also the focus of a collaborative TRANSGOV-CEEW report, which found that while globally emissions need to reduce by at least 43% by 2030, developed countries’ NDCs only add up to 36%, and that self-reported projections point to a mere 11% reduction. In other words, these self-reported projections are a potentially powerful tool to track progress in meeting NDCs (as TRANSGOV reported on also earlier at COP28 as contained in the post below).
Secondly, the synthesis report also notes, in paragraph 32, that emissions in developed countries only decreased by 17.3 per cent between 1990 and 2021.[10] This is politically salient in the context of the Global Stocktake outcome, which noted ‘with concern the pre-2020 gaps in both mitigation ambition and implementation by developed country Parties and that the Intergovernmental Panel on Climate Change had earlier indicated that developed countries must reduce emissions by 25–40 per cent below 1990 levels by 2020, which was not achieved.’[11] The synthesis report of self-reported emission information by developed countries thus contains a final verdict on whether certain benchmarks of collective action were reached.
Finally, the synthesis report also covers reporting on the controversial topic of climate finance. Here it found, based on self-reported data by developed countries, that ‘climate finance, including climate-specific and core/general contributions, provided by developed countries to developing countries averaged USD 51.6 billion annually in 2019–2020’.[12] This is again politically salient information in the context of the goal for developed countries to provide 100 billion in climate finance annually by 2020.
At COP28, countries did not manage to reach consensus on the consideration of this synthesis report. Then at the opening of the June sessions at the 60th session of the subsidiary bodies, Brazil made a small fuzz in the opening plenary demanding this item be discussed in a dedicated negation room. The crux in these Bonn negotiation sessions was what to do with the pieces of information outlined above. Negotiations led to an informal note, which contained an option to simply note the synthesis report and an option to signal out key pieces of vital information and invite developed countries to submit additional information on how they have used the outcomes of this consideration to take on additional policy measures. But no agreement was reached in Bonn on this matter,[13] meaning all options are still on the table at COP29, with implications for how transparency gets translated into action.
Conclusion
Transparency will feature prominently at COP29, including in the focus of the presidency’s events and diplomatic efforts. There will be celebration of those countries who already submitted their first biennial transparency reports under the enhanced transparency framework and there will be a strong call for those who have not yet done so to submit before the deadline of December 31 this year. While the start of the enhanced transparency framework and early biennial transparency report submissions will catch the limelight, crucial discussions on climate transparency will take place in smaller negotiation rooms or side events. As outlined in this blogpost these relate to how to translate key findings coming out of the pre-Paris transparency reports into action, how to rethink support for reporting and new developments in reporting on adaptation and loss and damage.
TRANSGOV will follow these matters at COP29 and continue to critically interrogate what transparency delivers in practice and whose priorities are reflected in the further implementation of the enhanced transparency framework.
[1] Least developed countries and small island developing states can submit at their discretion.
[2] As of November 6, 2024. Available at https://unfccc.int/first-biennial-transparency-reports.
[3] This side-event is titled ‘Learning from BTR reviews: Experiences from the in-country review of Guyana’s first BTR’ and will take place on Monday 18th November at 15:00 in side-event room 7. Available at: https://seors.unfccc.int/applications/seors/reports/events_list.html?session_id=COP%2029.
[4] See also: Weikmans, R., & Gupta, A. (2021). Assessing state compliance with multilateral climate transparency requirements: ‘Transparency Adherence Indices’ and their research and policy implications. Climate Policy, 21(5), 635–651. https://doi.org/10.1080/14693062.2021.1895705. Available at: https://www.tandfonline.com/doi/full/10.1080/14693062.2021.1895705#abstract.
[5] Mayer, Benoit, Transparency under the Paris Rulebook: An Enhanced Transparency Framework? (September 3, 2019). (2019) 9:1 Climate Law 40-64, Available at SSRN: https://ssrn.com/abstract=3447126
[6] Konrad, S., van Deursen, M., & Gupta, A. (2021). Capacity building for climate transparency: neutral ‘means of implementation’ or generating political effects? Climate Policy, 22(5), 557–575. https://doi.org/10.1080/14693062.2021.1986364
[7] See the draft outline of this loss and damage reporting guidance here: https://unfccc.int/sites/default/files/resource/BTR%20Guidelines%20Outline.pdf
[8] See, for example: https://www.ceew.in/sites/default/files/ceew-what-gets-measured-gets-done-transparency-for-loss-and-damage-04nov24-web.pdf; https://climateanalytics.org/publications/using-existing-databases-to-report-on-loss-and-damage-in-biennial-transparency-reports-under-the-unfccc .
[9] Pulles, T., & Hanle, L. (2023). A fit for purpose approach for reporting and review under UNFCCC’s Enhanced Transparency Framework. Carbon Management, 14(1). https://doi.org/10.1080/17583004.2023.2235568.
[10] Excluding emissions from Land Use, Land-Use Change and Forestry.
[11] 1/CMA.5, para. 17. https://undocs.org/FCCC/PA/CMA/2023/16/Add.1
[12] 1/CMA.5, para. 202. https://undocs.org/FCCC/PA/CMA/2023/16/Add.1
[13] For an article further discussion this see: https://www.twn.my/title2/climate/info.service/2024/cc240606.htm
TRANSGOV 