Transparency at COP27: Five key outcomes

Before COP27 we published this blogpost outlining 5 key processes related to transparency to follow.  This blogpost reflects on the key outcomes.

The high-level opening ceremony of the #Together4Transparency initiative at COP27. Picture credit UN climate change

1.    The voluntary review of adaptation (and loss and damage) information: agreed!

As we reported in our pre-COP27 blog, under current transparency rules, there is no provision for technical review of information submitted on adaptation (and loss and damage). Key on the COP-27 transparency agenda was a request by developing countries to permit voluntary review of such information. Developed countries were not keen to have such information undergo review. 

At COP27, Parties decided that countries may voluntarily submit information on adaptation (and loss and damage) for technical expert review.

One outstanding item was whether countries should be allowed to submit only one subsection of the adaptation section (crucially, one of the subsections is about loss and damage) for review. In Sharm-el Sheik, countries landed on the compromise text that if a country submits this section for review, all information in it will be reviewed, but certain sections can be identified for extra attention by the reviewers.

The hope is that including adaptation information in the review process will help to improve adaptation reporting capacities. As noted by an attendee at a COP27 #Together4transparency event, the focus of reporting capacity is often on emissions and mitigation. Similarly, earlier TRANSGOV work (link and link) has shown how capacity building programmes tend to focus less on adaptation. Whether this new provision to allow for voluntary review of adaptation information will help to improve adaptation reporting capacities remains to be seen.  

Read the adopted decision text on this matter.

2.    Carbon markets: confidentiality and double counting

As we reported in our pre-COP27 blog, reporting on use of market mechanisms (Article 6) was a key item on the agenda. Article 6.2 allows countries to bilaterally or multilaterally trade emission reduction credits and then report on these trades, with this information undergoing review before being made public. However, countries can mark certain information as ‘confidential’. At COP27, Parties were to decide the scope of this confidentiality provision. 

2.1 Confidentiality

Confidentiality provisions under article 6.2 were up for debate till the very last minutes of COP27.

The decision text on article 6.2 allows countries to identify certain information as confidential, thus not publicly available. However, countries should then justify why the information is confidential. Technical reviewers can still review the information and shall publish inconsistencies found, but in a manner that does not compromise confidentiality of the information.

The SBSTA will continue to further discuss modalities of review of confidential information at the next session. Countries can submit their views on this matter before the next June intersessional.

The fear is that evoking confidentiality may hide emission reduction credits of questionable integrity.

2.2 Double counting

Another key issue that emerged, under article 6.4, was loopholes that would allow the selling of emission reductions twice (or even more). Despite detailed rules for GHG inventories, such trades could give a false sense of emission reduction achievements.

COP26 decided that host countries, where projects generating credits are based, should make ‘corresponding adjustments’ when selling credits to other countries. However, this only applies to ‘authorized’ credits. At COP27, a key question was what to do with unauthorized credits. COP27 ultimately termed these credits ‘mitigation contributions’, based on the philosophy that buying these credits  should be seen as a form of (international) financing of emission reductions that will count towards the NDC target of the host country, rather than offsetting the buyer’s own emission reductions.  However, the system is not watertight and buyers may in practice still count the credits towards their own climate goals.

Tricky issues related to emissions avoided and emission removals will be discussed at future sessions.

3.    Unresolved: outstanding matters under the Pre-Paris transparency regime

As we reported in our pre-COP27 blog, Parties were to consider ‘compilation and synthesis’ reports prepared by the UNFCCC secretariat that synthesized the performance of developed (annex I) countries, as reflected in their transparency reports. This is valuable source of information about such performance.

As expected, however, the COP decided to defer consideration of the Annex I BR synthesis report to the next session. The reason? Russia reports emissions from Crimea. Ukraine and allies thus oppose giving such a synthesis report any formal consideration. This is unfortunate because these reports contained valuable politically salient information on how developed countries performed on their 2020 mitigation and climate finance targets, as we explain in detail in our pre-COP27 blog.

Looking forward, under the Enhanced Transparency Framework (ETF), the UNFCCC secretariat is mandated to write a synthesis report of Biennial Transparency Reports (BTRs) (18/CMA.1 paragraph 6(a)). This may lead to further negotiations— either before or in response to the first synthesis report. One question is whether the report should be disaggregated by developed and developing countries.

4.    A triangle? Transparency, finance and loss & damage

As we reported in our pre-COP27 blog, perhaps one of the most prominent and contentious expectations for COP27 was to address financing for loss and damage. 

A key outcome of COP27 is the establishment of a fund to respond to loss and damage.

A close reading of the decision text shows that parties established new funding arrangements (plural) and that one component of this is a new loss and damage fund.

It remains to be determined what the funding arrangements landscape will look like, and what role the newly established fund will play vis-à-vis other funding arrangements. One question we are interested in is how parametric insurance enabled by novel forms of satellite-enabled data relates to this, and whether such insurance-based instruments may crowd out public finance via the fund.

It is worth noting that the decision text does not mention that funding should be public and grant-based, despite calls for this by developing countries.

Although the decision text does not mention insurance either, it does mention the ‘Global Shield’ (an approach piloted by Germany and a host of private actors outside the auspices of the UNFCCC to address loss and damage through insurance schemes), as well as the need for ‘speed’ in reacting to instances of loss and damage. These elements provide avenues for the promotion of insurance—enabled through new forms of radical satellite-enabled transparency— as key to loss and damage financing. TRANSGOV will continue to follow this topic closely.

5.    A (mis)match? Transparency and ambition

As we reported in our pre-COP27 blog, the last year has seen the launch of the ‘work programme to urgently scale up mitigation ambition and implementation in this critical decade’. Transparency is presented as the backbone of ambitious climate action under the Paris Agreement and a key source of information about country performance. Will the mitigation work programme draw on transparency reports? Or will the two remain politically detached?

The decision text on the mitigation work programme does not mention Biennial Transparency Reports as a source of input. Instead, the only clear input to the work programme is to be targeted submissions by parties and non-party stakeholders. The transparency system thus remains detached from this important new agenda item that is explicitly designed to address the raising of collective ambition.

This seems to be a trend rather than an anomaly. For example, the Glasgow Climate Pact does not make any reference to findings from country transparency (BR or BUR) reports. Instead, information emphasized here is the forward-looking findings from the NDC synthesis report. The fact that these findings are not in line with the Paris Agreement’s 1.5-degree target is cited as the main reason for the need to double down on mitigation efforts. It is surprising however that no reference is made to actual findings from Parties’ transparency reports that cover implementation of targets.

It seems that the transparency arrangements and ambition-related negotiations remain politically detached. TRANSGOV will continue to follow this topic closely.  

6.    Other matters

While participating in COP27, two additional transparency-related matters caught our attention. First, the obscure but consequential agenda item on ‘bunker fuels’- that is, aviation and shipping; and second, the buzz around getting ready for the ETF.

6.1 (Not) Counting emissions from international aviation and shipping

Hidden under ‘methodological items under the convention’, we find the agenda item on bunker fuels. Bunker fuels are defined as all fuels sold for international aviation and shipping.

The UNFCCC has a clear explainer on this:

“The IPCC Guidelines for the preparation of greenhouse gas (GHG) inventories, the UNFCCC reporting guidelines on annual inventories for Parties included in Annex I to the Convention (Decision 24/CP.19), and the Modalities, procedures and guidelines for the transparency framework for action and support referred to in Article 13 of the Paris Agreement (Decision 18/CMA.1) outline that emissions from international aviation and maritime transport (also known as international bunker fuel emissions) should be calculated as part of the national GHG inventories of Parties, but should be excluded from national totals and reported separately.

These emissions are not subject to the limitation and reduction commitments of Annex I Parties under the Convention and the Kyoto Protocol due to the fact that they are not accounted in national totals.”


In simple terms, this means that emissions from international shipping and aviation do not count towards any country’s emissions.

This is reason for concern because these emissions are on the rise:

Source: BR synthesis report

Rather than counting these emissions in the inventories, the UNFCCC is ‘in dialogue’ with ICAO and IMO to keep tabs on how these organizations aim to reduce emissions and how they are counted. At COP27, these organizations gave a presentation and they provided answers to some but not all questions.

6.2 Getting ready for the ETF

The Sharm el-Sheik Implementation Plan contains a dedicated section on transparency. This short section recalls the deadline for submission of the first BTR and urges parties to make necessary preparations to meet this deadline. It further recognizes the need for increased support to developing countries for implementing the ETF.

During COP27, the UNFCCC secretariat organized 25 events under the banner #Together4Transparency. The event series is to celebrate past achievements and “pave the way for the full implementation of the Enhanced Transparency Framework (ETF) of the Paris Agreement”.

The event series included various organizations that provide capacity building support. As mentioned by one speaker, “there is support out there”. It seems that donor countries are relatively willing to spend resources on ensuring that developing countries meet the Paris Agreement’s transparency obligations.

One session was titled “Benefits and tools for implementing the Enhanced Transparency Framework”.

The UNFCCC secretariat presented a list of benefits that may result from participating in the UNFCCC transparency arrangements.

The UNFCCC secretariat presenting the benefits of transparency. Thursday 17 Nov, 2022. COP27, Egypt. Picture credit: Max van Deursen

TRANSGOV will do further empirical research to analyze what the consequences of participation in transparency arrangements are in practice, particularly in relation to climate action. We will do this also through in-depth country case studies.


Transparency did not make headlines at this COP-27. However, transparency related fights flared up in various other negotiations, including climate finance, mitigation ambition and market mechanisms. This said, the overall picture that emerges is that of an isolated transparency framework. There are few institutional linkages between the transparency framework and other politically contentious negotiation processes aimed at ramping up ambition, like the mitigation work programme or the discussions on the new collective quantified goal on climate finance. Even as this is so, efforts to get as many developing countries up to speed with  UNFCCC and ETF reporting requirements continue unabated.

Transparency at COP27: follow these five processes    

COP27 is around the corner. What to expect for transparency negotiations? At first glance, it may seem like intensive transparency negotiations are now a thing of the past. The rules for the Enhanced Transparency Framework of the Paris Agreement are described by the Modalities, procedures and guidelines from Katowice and the reporting guidance from Glasgow. What is left for transparency at COP27? This blogpost highlights that transparency’s tentacles penetrate various domains of the UNFCCC. We highlight five processes to follow to understand how transparency’s role in climate governance evolves. 

Delegates at COP27. Picture credit Kiara Worth

1.    Voluntary review of adaptation and loss & damage information

Glasgow marked the end of six years of tedious negotiations to hammer out the detailed transparency rules under the Paris Agreement. Or, so it seemed. In Bonn last June, negotiations re-opened on the question of whether information related to adaptation and loss and damage could undergo technical review on a voluntary basis.

Under current rules, there is no technical review of information on adaptation and loss and damage as reported by countries. Yet, adaptation and loss and damage are important topics for developing countries.

Developing countries argue they should have the opportunity to ask for voluntary review of this information. The quality of reporting on adaptation and loss and damage is far behind mitigation. Undergoing technical review may improve reporting capacity.

Developed countries are less keen to have adaptation and loss and damage undergo review. They fear the international community will spread its resources thin if too many types of information have to be reviewed. Thus, developed countries defend, the focus should be on emissions and mitigation.

In Bonn, it became clear that the idea of a voluntary review option was politically palatable. However, the devil is in the detail- this one a detail with implications for review of loss and damage information.

Under the Paris Agreement adaptation and loss and damage are treated as two separate items, each with its own article. However, under the transparency rules, loss and damage is a subsection under the category ‘adaptation and climate impacts’.

The discussion in Bonn centered around whether countries should be allowed to only submit one subsection (i.e. loss and damage) for review, if they wish so. Developed countries were against. This matter remains bracketed in the text going into COP27 (See draft text para 3: “decides that the Party undergoing the review referred to in paragraph 1 above may elect all information or specific topics within the information reported”).

Another discussion in Bonn centered around whether the review team should include loss and damage experts. And whether the training programme for reviewers should have a separate module on loss and damage. But these suggestions did not make it to the draft text coming out of SB56 in Bonn.

 “AOSIS members wanted an option for loss and damage experts to review the voluntary information that we report. This proved too much to ask.”

– AOSIS closing statement submission at SB56 in Bonn

At COP27, negotiators will finalize the decision text on this matter. This discussion illustrates the political nature of transparency negotiations. Moreover, it shows how contentious issues (e.g, how much attention for loss and damage) get hammered out in operational detail in the transparency negotiations.

2.    Confidentiality and reporting on the use of market mechanisms

Under the umbrella of Article 6 (market mechanism) negotiations, Parties will discuss the details of reporting on the use of market mechanisms.

As highlighted by a article the question for COP27 is: “will countries agree to full transparency on carbon credit trades under Article 6.2?”

Article 6.2 allows for countries to bilaterally or multilaterally trade emission reduction credits. Countries have to report on these trades and this information then undergoes review which is in turn made public.

However, the current rules have a provision where countries can mark certain information ‘confidential’. At COP27 Parties will debate this confidentiality provision. Carbon brief did an analysis of country positions for COP27. Like Minded Developing Countries want all information to be treated as confidential by default. The EU, Small Island Developing States, and Least Developed Countries oppose such blanket confidentiality.

3.    Unresolved: outstanding matters under the Pre-Paris transparency regime

COP27 will also feature agenda items on pre-Paris transparency arrangements. Two sub-agenda items are of particular interest.

First, Parties will consider ‘compilation and synthesis’ reports that capture the performance of developed (annex I) countries (agenda item SBI 3b). Under the convention, developed countries have to submit Biennial Reports on progress towards mitigation pledges and climate finance. The UNFCCC secretariat then drafts a ‘compilation and synthesis’ report that shows overall progress of annex one countries on mitigation and climate finance.

Upon publication of these reports, Parties are to ‘consider’ its content. This is a sticky point. Parties did not manage to agree on their consideration of the ‘compilation and synthesis’ reports from 2016, 2018, and the recently updated report from 2020.

An example, of information in this report includes aggregated figures of time-series of annex-1 Party emissions and climate finance. (page 14)

It remains to be seen if Parties can conclude their consideration of these reports at COP27.

The other outstanding item also involved ‘consideration’ of reports (agenda item SBI 4a). This time reports submitted by developing countries (non-annex 1). Back in 2006, some Parties argued that under Article 10.2 of the Convention the SBI is to consider National Communications by non-Annex 1 countries (developing countries). This agenda item has since been held in abeyance. At COP27 Parties are invited to provide guidance on how these reports may be considered.

These ‘considerations’ are moments where reporting meets the political process.  Reporting is one thing, but to act on the findings of the reports- or to agree on the content in the reports- is another.

4.    A triangle? Transparency, finance and loss & damage

Perhaps one of the most prominent and contentious expectations for COP27 is to move forward on finance for loss and damage. The G77/China submitted a new agenda item on this matter for COP27 titled “Matters relating to funding arrangements for addressing loss and damage”.

While finance for loss and damage is no longer taboo, views on how to operationalize it diverge. One approach piloted by Germany and a host of private actors is to address loss and damage through insurance schemes.

Transparency is a crucial factor here. First, novel technologies such as satellite-based monitoring make possible new parametric insurance products for extreme weather events such as drought. Second, donor countries will want to report on the finance provided to these insurance schemes as climate finance. But views diverge as to how amounts should be calculated. Moreover, much uncertainty persist around whether and how insurance schemes will align with principles of climate justice such as polluter-pays and common but differentiated responsibilities enshrined under the Convention.

5.    A (mis)match? Transparency and ambition

Ambition is a word that sparked fierce debate at the previous climate talks in Bonn. The latest synthesis report shows that countries are off track to keep temperatures below the agreed 2 degree goal, let alone 1.5. (Similar conclusions in the second periodic review).

In Glasgow, the ‘work programme to urgently scale up mitigation ambition and implementation in this critical decade’ was established to ramp up ambition. In Bonn, discussions on operationalizing this programme were contentious and did not yield any outcome documents.

If the mitigation work programme is to ramp up ambition, then what does it draw on to discuss who should do more and when?

Transparency is often assumed to be the backbone of ambitious climate action and the key source of information. Will the mitigation work programme at any point draw on transparency reports? Or do the two remain politically detached?

Nothing is set in stone yet. The AOSIS submission to the work programme suggest that Biennial Transparency Reports will be an input for the work programme. By contrast, Australia and Norway do not list Biennial Transparency Reports as inputs. Rather, they prefer NDC and long-term net-zero pledges as inputs. This may indicate their reluctance to have scrutiny about actual past implementations.


Transparency may not make the headlines this year. However, its tentacles penetrate various domains of high-stake negotiations, including loss and damage and enhanced ambition. Moreover, routine negotiations to consider transparency reports have proved difficult. At the same time there are a series of events about ‘getting ready for the ETF’ under the #together4transparency initiative. What does this mean for the prospects of the Enhanced Transparency Framework? These and other questions remain open-ended and will be on our mind during COP27.

TRANSGOV representatives will be at COP27 to cover the latest transparency developments. Follow daily updates via the TRANSGOV twitter.

Capacity building for climate transparency: A database and dashboard of CBIT projects

Capacity building for climate transparency is generally understood as a neutral means to ensure all countries have the capacity to report information to the UNFCCC. However, an earlier TRANSGOV article problematized this proposition and highlighted that capacity building may in practice steer the type of transparency generated by countries and influence politically contested discussions over who is to be transparent about what to whom. In particular, the article interrogated whether and how capacity building initiatives steer or preempt options for developing countries trying to navigate between adhering to global transparency provisions (which emphasize transparency of emissions and mitigation action) versus furthering domestic aims (which may relate more to generating information on adaptation, loss and damage, and finance).

The article called for empirical analysis of capacity building in practice. This blogpost takes a next step in this line of research and presents a database of capacity building for climate transparency projects as a first step in taking this research agenda forward and as a resource for others to use as well.

Capacity building and climate reporting requirements

Climate transparency provisions for developing countries have become more demanding with the adoption of the 2015 Paris Agreement. From 2024 onwards, developing countries (with the exception of Least Developed Countries and Small Island Developing States) need to biennially report to the UNFCCC on a range of topics. However, not all developing countries have the capacity to meet reporting provisions under the new system. Indeed, reporting can be a challenging affair, involving data collection, management, and compilation across various sectors of government.

In response to developing countries’ capacity concerns, a Capacity-building Initiative for Transparency (CBIT) has now been established under the UNFCCC to help developing countries, including Least Developed Countries and Small Island Developing States, to meet reporting requirements. The CBIT has been set up as a trust fund under the Global Environmental Facility (GEF) with substantial resources from developed countries at its disposal.

Climate reporting under the Paris Agreement consists of four areas: reporting on greenhouse gas (GHG) inventories, mitigation actions, climate impacts and adaptation actions, and financial and other support provided, needed and received. For developing countries, only the first two of these areas of reporting are mandatory. Yet, adaptation and finance are important for some developing countries, and the Paris Agreement outlines that countries should report on these areas as well.

Mandatory and optional reporting provisions for developing countries

What capacities are prioritized in practice?

The CBIT allows for funds to be requested for building reporting capacities for each of the four areas of reporting. With the CBIT now underway for several years, it is timely to ask which areas of reporting are being prioritized by developing countries in requesting funding.

GEF’s annual CBIT update reports give some indication that mandatory reporting requirements are prioritized, but that adaptation and finance are also addressed. However, the GEF reports only give a macro and summary estimate and do not allow for disaggregation.

To allow for a more comprehensive and robust assessment, we have now developed a database with information on the thematic focus of CBIT projects. Importantly, this database uses as its data source the approved Project Identification Forms (PIF) submitted by countries applying for CBIT funds. This is a rich source of primary information to more fully assess the areas of capacity building for which support is being requested. Each of these PIF documents contain project components and outputs, including the amount of funding requested for each.

Our database takes the first step to classify each project component based on the four key pillars of reporting (GHG inventory, mitigation, adaptation, support) and identifies the corresponding amount of funding requested. A key finding is that the lion share of requested CBIT funding is for developing capacities to report on GHG inventories and mitigation action. The respective sums are 25.9 million USD for GHG inventory reporting, 24.4 million USD for mitigation reporting, 8.0 million USD for reporting on adaptation and climate impacts, and 5.6 million USD for reporting on support needed and received. Some project components and outputs do not specify any of the four pillars, and were classified as undefined amounting to 25.5 million USD. The observed pattern of prioritization of GHG inventory and mitigation holds across time, regions, and also among Least Developed Countries and Small Island Developing States. Among the implementing agencies that execute the CBIT projects, the Food and Agriculture Organization (FAO) is the odd one out, with considerable support being requested for adaptation projects. This is likely due to the fact that the Food and Agriculture Organization is specialized in the Agriculture, Forestry and Land Use (AFOLU) sector, which is a priority adaptation sector in many developing countries.

The lion share of requested CBIT funds focuses on developing capacities for reporting on GHG inventory and mitigation


The database shows that most capacity building resources under the CBIT are requested for GHG inventory and mitigation reporting. As discussed in a previous blogpost, this may not be surprising given that these are the mandatory categories of reporting. Yet it does raise questions as to whether resources are used in line with national priorities. Indeed, developing countries have been calling for reporting on adaptation and support in the negotiations.[1] For example, in a submission for a negotiation session on transparency in 2017, South Africa stated that reporting information to track adaptation “represents a very important enhancement of the transparency framework.”[2]

Further empirical in-depth analysis is needed to see how developing countries balance domestic needs against global expectations. The database and dashboard presented here can facilitate taking this next step.

An interactive dashboard to explore areas of reporting for which CBIT funding is requested
An interactive dashboard to explore areas of reporting for which CBIT funding is requested

The CBIT dashboard and database can be downloaded here and used freely (if cited) for future research.

For any queries, please contact the author, TRANSGOV PhD researcher Max van Deursen, at Suggested citation:

Deursen, van M. (2022). Database of CBIT projects (Version V20211228) [Data set]. TRANSGOV.  

[1] Susanne Konrad, Max van Deursen & Aarti Gupta (2021) Capacity building for climate transparency: neutral ‘means of implementation’ or generating political effects? Climate Policy, DOI: 10.1080/14693062.2021.1986364

[2] South Africa (2017). Submission by South Africa to the Ad Hoc Working Group on the Paris Agreement on Transparency of Action and Support. Retrieved from:

An assessment of capacity building for climate transparency under the UNFCCC

This blog post is based on the recently published article in Climate Policy by Susanne Konrad, Max van Deursen & Aarti Gupta

Elaborate transparency systems are now at the core of the 2015 Paris Agreement, with the assumption that this will enhance accountability, trust, and greater climate policy ambition. With transparency becoming ever more central, much attention is being devoted to building the capacity of developing countries to participate in UNFCCC transparency arrangements. Yet what might capacity building deliver and for whom? And (how) does capacity-building steer the kind of transparency to be generated? To address those questions, the authors conducted a three-part review into transparency-related capacity-building, comprising a literature review, an analysis of country submissions as well as a review of two major capacity-building initiatives.

A growing ecosystem of capacity building initiatives

The Paris Agreement adopted strong language by noting that capacity building support for transparency shall be provided on a continuous basis, signaling a change from previous ad hoc capacity-building support. Moreover, a dedicated fund called the Capacity-building Initiative for Transparency (CBIT) was established in 2015 to channel resources from developed countries to capacity building efforts in developing countries. A complex ecosystem of initiatives has emerged providing various types of support to build transparency capacities in developing countries. While a comprehensive mapping of the capacity building landscape is beyond the scope of this blogpost, prominent initiatives include the Partnership on Transparency in the Paris Agreement (PATPA) and Initiative for Climate Action Transparency (ICAT). Other initiatives and actors include, among other, the Consultative Group of Experts (CGE), Caribbean Cooperative MRV Hub (CCMRVH), the Nationally Determined Contributions (NDC) Partnership and the Partnership for Market Readiness, and. We have examined the two initiatives CBIT and ICAT more closely.

Neutral ‘means of implementation’ or generating political effects?

The next years will be crucial for the way in which transparency provisions become institutionalized

Capacity building is often framed as a neutral ‘means of implementation, i.e., a tool to achieve already established and widely shared ends. However, capacity building operates in the political context of climate governance. In particular, questions over ‘who should make what visible, to whom, and why’ are highly politically salient and remain contested within global climate politics. In theory, the scope and extent of transparency to be generated by countries has been decided upon in multilateral negotiations through the Paris Agreement and its “Enhanced Transparency Framework” provisions. However, the interpretation and implementation of these provisions can go in various directions. Moreover, the transparency provisions themselves are the outcome of political compromise and may not be equally fit for all countries’ circumstances. The next years will be crucial for the way in which transparency provisions become institutionalized, particularly in developing countries, and transparency-related capacity building initiatives may steer this process. In particular, they may steer the scope and extent of transparency generated. We draw out these steering effects by examining the ‘what, how and who’ of capacity building efforts.

What capacities? Mitigation reporting prioritized

Capacity building is a broad term that allows for many activities to go under its name. Capacities may stretch all the way from capacity of an individual to use a certain software to the capacity of entire public administration systems to coherently implement policy. In the context of the UNFCCC, the thematic focus of capacity building for transparency is of importance. Capacity building could focus on reporting on greenhouse gas emissions, mitigation, adaptation, support, and loss and damage. The formal transparency provisions establish that reporting on greenhouse gas emissions and mitigation actions is mandatory while adaptation and support (received and needed) are voluntary categories of reporting.

Developing countries have voiced through submissions to the UNFCCC that they find reporting on all of the above categories important, while developed countries tend to emphasize GHG inventory and mitigation reporting.

The two large capacity building initiatives, CBIT and ICAT, in theory allow for capacity building on all thematic areas but in practice prioritize building capacities for mitigation and GHG inventory reporting, even in least developed countries and small island developing states.

How are capacities built? The ad hoc project-based approach lingers on

Several scholars and practitioners alike have criticized past transparency-related capacity building efforts as being too consultant-driven, project-based and short-term. As a result, capacities were not properly built or retained in countries upon completion of a project or report. With the Paris Agreement making biennial reporting mandatory for developing countries, a general narrative has emerged that capacity building support should transition from the prior ad hoc arrangements to structural support packages, addressing individual and institutional capacities alike. Yet, in practice, the main capacity building initiatives, CBIT and ICAT, essentially still operate on a project-based approach, where countries have to go through new application cycles each time they want to set up a new project after one project concludes. Nevertheless, developing countries do appreciate the CBIT as a source of multilateral funding as opposed to, or in addition to, bilateral arrangements, also given its large size.

Who builds whose capacities?

A key question is whether transparency-related capacity building efforts should focus on those countries with least capacities or whether other (strategic) considerations should be taken into account in selecting countries to receive support. CBIT is open to all developing countries to apply for funding, and has allocated a substantial amount of funding support to projects in least developed countries and small island developing states. ICAT adopts strategic criteria in the selection of projects, such as countries’ greenhouse gas emissions and leadership potential.

CBIT and ICAT fund and facilitate capacity building projects but these projects are often executed in collaboration with organisations such as UNDP, UNEP DTU Partnership, and the Greenhouse Gas Management Institute. While working closely with the developed countries, these organisations could steer the transparency-related capacity-building efforts in certain directions.  A key challenge here is to balance the priorities and expertise of these agencies with the context-specific priorities and expertise at the national level.

One size fits all?

One important insight is that the scope and mandate of the Paris Agreement’s transparency framework is driving a focus on GHG inventories and mitigation actions in capacity-building projects across the globe. This is clearly linked to the mandatory nature of these reporting obligations. While this may be unsurprising, it does establish that the politically negotiated scope of the UNFCCC’s mandatory transparency requirements is indeed being institutionalized and diffused to the country-level via capacity-building initiatives.

Some strands of scholarly literature do critically interrogate whether the GHG inventory and mitigation focus within the Paris Agreement’s transparency mechanism is, or should be, a priority for many developing countries, as compared to reporting on adaptation, loss and damage, and/or support needed and received. While the need for capacity building to report on adaptation or support is not entirely missing from existing practices, it is more marginal than expected, suggesting that the voluntary nature of reporting on these aspects plays a role in such marginalization. To some extent, this is inevitable, given scarce resources and the need to deploy these to comply, first and foremost, with mandatory UNFCCC reporting obligations. In practice, however, this privileges the generation of specific types of transparency, with potential consequences for the climate actions prioritized by countries. It can result in generating detailed greenhouse gas inventories within countries with low emissions and even lower capacities to mitigate, at the expense of building up reporting and assessment capacities on climate vulnerability, adaptation and loss and damage.


Our analysis suggests that, instead of being merely a ‘neutral means of implementation’, capacity building has the potential to influence highly politically salient decisions about ‘who should make what visible, to whom, and why’ in the contested context of global climate politics. As critical scholarship highlights, transparency’s role in furthering trust, accountability and climate ambition is widely assumed but currently more asserted than empirically demonstrated. In addition, such diverse governance ends – furthering trust, accountability, and climate ambition – have quite distinct implications for the scope of transparency to be generated and from whom, and thus also for associated capacity-building efforts.

There is a need to continue to empirically assess the steering effects of capacity-building initiatives that support ever-greater levels of mitigation-related reporting from developing countries, while other politically salient categories – such as reporting on adaptation, support needed and received, or loss and damage – may go underprioritized. As such, we also need to critically interrogate the still widespread assumption that ever greater transparency from all is vital to  effectively addressing the climate challenge.

Transparency of (in)Action? Eight key matters to follow in the COP26 transparency negotiations

COP26 is just around the corner. What to expect? Key negotiation items on the agenda are common timeframes for NDCs, market mechanisms, climate finance and transparency. Indeed, transparency is one of the most contentious negotiation items, with talks on this item closed to observers at the preceding intersessional session in May-June 2021. This blogpost outlines key issues central to the transparency negotiations at COP26.

‘New transparency’: The Enhanced Transparency Framework

Perhaps the most contentious transparency negotiations will be those on the ‘new’ Enhanced Transparency Framework that was established under the Paris Agreement. While most of the provisions of this framework have already been decided upon, some key matters remain. At first glance they may seem purely technical, but we argue that these matters represent larger political questions of bifurcation and fairness.

1: Countries will discuss common formats for reporting (in a bifurcated world?)

At COP26, outstanding matters relating to the Enhanced Transparency Framework will be discussed under SBSTA-agenda item 14. This includes scoping out common (tabular) templates and formats for reporting on greenhouse gas emissions, progress in implementing nationally determined contributions, and provision of financial support.

In contrast to earlier transparency provisions, the Enhanced Transparency Framework applies to all countries, with flexibility given to developing countries with limited reporting capacities. However, analyses of existing transparency arrangements under the UNFCCC reveal very different levels of reporting capacities between countries. This, coupled with the fact that some countries are reluctant to step away from a bifurcated system of reporting, might make it very challenging to agree upon common reporting templates.

2: Countries will discuss the Biennial Transparency Report outline: what is in and what is out?

At the core of the Enhanced Transparency Framework is the Biennial Transparency Report, to be submitted by all countries (with special leeway given to least developed countries and small island developing states). The Paris Agreement outlines in broad lines what countries should report on in these Biennial Transparency Reports. This includes as mandatory elements reporting on greenhouse gas emissions and mitigation action (and financial support provided by developed countries), and as voluntary elements reporting on adaptation, climate impacts and financial support needed and received by developing countries.

However, countries have yet to agree on the outline of this Biennial Transparency Report. There is significant division on whether the outline should be the same for all countries, if it should be obligatory to follow the outline, and whether the outline should focus on the mandatory elements of reporting (emissions and mitigation) or also on the voluntary elements.

3: Countries will discuss the Technical Expert Review: what will it (not) cover?

Similar questions arise regarding the outline of Technical Expert Review Reports of the Biennial Transparency Reports. What if countries report on Loss and Damage, should reviewers assess this information? Then there is also the issue of flexibility: developing countries can use flexibility in complying with reporting obligations, depending upon their capacities. But (how) should reviewers take into account flexibility?

This segues into discussions on the training programme for technical expert reviewers. Should the training programme also include an element on Loss and Damage, or is this out of the scope? And what will reviewers learn about considering flexibility provisions?

or will developed countries go a ‘step back’ in terms of the stringency of review they need to undergo?

In fact, these questions about the technical review may only be the start of a much more contentious discussion about what review as a whole will look like under the Enhanced Transparency Framework. Until now, developed countries have faced rather stringent review of their submitted reports (both under the Kyoto Protocol and the UNFCCC) while review of information submitted by developing countries has been much more of a facilitative nature. With the Enhanced Transparency Framework being a common system, the question is what direction the pendulum will swing, will developing countries face more stringent review, or will developed countries go a ‘step back’ in terms of the stringency of review they need to undergo? Or may the review system introduce bifurcated provisions after all? These questions are likely not to be resolved until shortly before the 2024 deadline of the start of the Enhanced Transparency Framework, but COP26 may see some initial careful moves in this debate. 

4: Countries will discuss the Compliance Committee: will the Paris Agreement have teeth?

Another interesting matter for the transparency negotiations is the Paris Agreement’s  committee to facilitate implementation and promote compliance. The Compliance Committee could be a potential puzzle piece in ensuring that disclosed information on performance has consequences. Yet, what will be the role of this committee? Will it have the power to effectively deal with cases of non-compliance? At COP26 the committee will report on their work in 2020 and 2021, and this may be an occasion for discussion on the role of this committee.

5: Countries will discuss the Global Stocktake: what sources of input?

The Global Stocktake is a process with a five-year cycle where collective progress towards achieving the objectives of the Paris Agreement is assessed. Its aim is to ‘make visible’ the collective progress of countries, and thus use this information to inform political decisions as basis for the enhancement of countries’ climate plans, the nationally determined contributions. As such, it can be seen as a vital element of the transparency architecture of the Paris Agreement. But an important question remains:  how will information from the Enhanced Transparency Framework be effectively consolidated to meaningfully feed into the Global Stocktake? At COP26 countries will discuss ‘sources of input’ for the Global Stocktake under SBSTA-agenda item 9, thereby further scoping out how the Global Stocktake will take shape.

‘Old transparency’: reporting and review under the UNFCCC

Besides the discussions on how the ‘new’ transparency framework under the Paris Agreement will take shape, COP26 will also feature processes and negotiations on the ‘old transparency’ system of reporting and review under the UNFCCC, which are still in place until 2024.

6: What’s next for the International Assessment and Review and the International Consultation and Analysis?

As part of the International Assessment and Review ten developed countries will undergo Multilateral Assessment. In this session various reports of the country under review will be discussed including Biennial Reports and National Communications. As part of the International Consultation and Analysis seven developing countries will undergo Facilitative Sharing of Views. This session is explicitly facilitative in nature and discusses the Biennial Update Report.

Interestingly, COP26 will also feature negotiations on ‘revision of the modalities and procedures for international assessment and review’ under SBI-agenda item 3(d) and on ‘revision of the modalities and guidelines for international consultation and analysis’ under SBI-agenda item 4(e). What changes may be made for these last three years of review under the ‘old’ system?

7: The future of the Consultative Group of Experts: what is a fair representation?

A key body providing support to developing countries for building reporting capacities is the Consultative Group of Experts. The Consultative Group of Expert is a constituted body under the UNFCCC and has a large representation of developing countries in its membership. To illustrate, the developing to developed countries membership is 10:10 for the Standing Committee on Finance, while it is 15:6 for the Consultative Group of Experts. Developed countries are expected to push at COP26 to get a larger representation in the group. Why this push? And why now? At the same time, not only the membership but also the terms of reference of the Consultative Group of Experts will be under discussion, and developing countries want to expand the mandate of this group, while developed countries are hesitant, especially if their membership is not increased.

8: The interplay between Article 6 and Article 13: transparency around market mechanisms

the rules, modalities and procedures for Article 6 is still under discussion and remain controversial

Last but not least, decisions need to be taken by countries on how to report on the use Internationally Transferred Mitigation Outcomes (ITMOs). Several countries aspire to use of market mechanisms (Article 6) for reducing their GHG emissions, which they also need to state in their NDCs. However, while there is agreement on the modalities, procedures and guidelines for tracking progress and implementing the NDC (Article 13), the rules, modalities and procedures for Article 6 is still under discussion and remain controversial.

The CMA agenda includes agenda item 12(a) on ‘Guidance on cooperative approaches referred to in Article 6, paragraph 2, of the Paris Agreement’. This guidance could include provisions on reporting and review. An open question is how this reporting and review under article 6 will relate to and interplay with reporting and review under the Enhanced Transparency Framework (Article 13).

Conclusion: transparency as a site of politics

In sum, transparency is one of the main negotiation items at COP26. Its contentious nature indicates that transparency is at the core of the Paris Agreement and the UNFCCC, and that countries realize that the details of transparency provisions can be of influence in shaping climate governance directions and outcomes. That said, it remains important to critically interrogate the merits and implications of the growing prominence of transparency in climate governance, through examining the political implications of the negotiation agenda-items noted above, as we do in the TRANSGOV project.

TRANSGOV has representatives at COP26 to cover the latest transparency developments. Follow daily updates via the TRANSGOV twitter.

New research out: assessing state compliance with multilateral climate transparency requirements

In a recent scientific publication for the journal Climate Policy, Romain Weikmans and Aarti Gupta study an essential question about the relationship between transparency and climate ambition, namely whether countries adhere to the mandatory transparency requirements of the UNFCCC. By studying the expert reviews and analyses that the UNFCCC provides about country transparency reports, Weikmans and Gupta generate a set of ‘Transparency Adherence Indices’ that synthesize the nature and extent of developed and developing country engagement with the UNFCCC’s reporting requirements. Their findings point to an interesting hypothesis: could it be that, rather than transparency stimulating ambition, ambition stimulates more transparency? If this is the case, does transparency follow, rather than shape, political developments?

Here are the authors key policy insights:

  • The UNFCCC and its 2015 Paris Agreement call for ever greater climate transparency from all countries.  
  • We develop ‘Transparency Adherence Indices’ that reveal frequency of engagement and adherence to reporting requirements of both developed and developing countries. 
  • Our analysis shows very high levels of participation in transparency arrangements by developed country Parties, with the exceptions of Ukraine and the United States of America.
  • The level of participation of developing country Parties is relatively low, especially among Least Developed Countries and Small Island Developing States. 
  • Further research to explain the range of observed adherence patterns is important, in light of the Paris Agreement’s requirements for enhanced transparency from all.  
  • The assumed link between enhanced transparency and climate action needs further analysis. 

The research article is fully open access and can be found here. A blog post that summarizes the article’s main messages can be found here.

Transparency Adherence Indices: A first step in assessing country compliance with global climate transparency requirements

This blog post is based on the recently published article in Climate Policy by Romain Weikmans & Aarti Gupta

One of the few legally binding obligations of the 2015 Paris Agreement is for countries to be transparent to each other about what they are doing with regard to climate change. This can include sharing information about domestic measures to reduce greenhouse gas emissions or to adapt to climate change. But the call for transparency is not new to the United Nations Framework Convention on Climate Change (UNFCCC). Since 1992, countries that have ratified this international treaty have to regularly communicate how they are implementing it, with requirements in place regarding what information is to be reported, by whom, how and when.

Transparency or climate ambition: what comes first?

Yet what transformative effects does such transparency generate? Many academics and policymakers assume that increased transparency is necessary to build trust, enhance accountability and ultimately stimulate ambitious climate action from all countries in this global climate governance context. Yet, these assumed links between transparency, accountability, trust and ambition have not been thoroughly interrogated nor empirically documented. It is therefore unclear whether transparency actually fosters such desired political developments; or if it is perhaps even the other way around. An intriguing hypothesis is that those who are already more ambitious in their actions and intentions are more prone to be transparent.

The relationship between transparency and climate action is thus crucial and timely to examine further. Yet we know very little currently about the extent to which countries are even complying with UNFCCC transparency requirements. This is why we undertake one of the first systematic assessments of the nature and extent of country engagement with current UNFCCC transparency arrangements, in an article just published in Climate Policy entitled “Assessing state compliance with multilateral climate transparency requirements: ‘Transparency Adherence Indices’ and their research and policy implications.”

To what extent are countries complying with global climate transparency requirements?

Our focus is on the transparency arrangements agreed by countries in 2010 and being implemented since 2014. These require countries to generate biennial (update) reports, which are subject to an UNFCCC-coordinated technical expert review or analysis. Drawing on the outputs of these technical expert reports, we generate ‘Transparency Adherence Indices’ in our article. These synthesize the nature and extent of developed and developing country engagement in UNFCCC transparency arrangements and adherence to reporting requirements. We also identify a research and policy agenda to help explain observed patterns of adherence.

Finding 1: Developed countries, selectively transparent

Our findings reveal wide variations in adherence to mandatory UNFCCC reporting requirements, and no clear general pattern of improvement since 2014. Specifically, the Transparency Adherence Index for developed countries shows Finland leading in adherence to mandatory UNFCCC reporting requirements, while the United States appears last on this list, primarily because it did not submit its third Biennial Report, due during the Trump administration’s tenure. In addition, Turkey, Estonia, Czech Republic, Romania, and Lithuania lead in transparency adherence within a sub-group of developed countries with economies in transition. The Russian Federation occupies the 12th position out of a total of 20 countries on this list of countries with economies in transition, with Ukraine appearing last because it has submitted only one biennial report thus far.

Further trends for all developed countries reveal that reporting requirements on greenhouse gas emissions are on average adhered to the most, with countries struggling to adhere to reporting requirements on achieving mitigation targets, and even more so, on support provided to developing countries, both highly salient categories of climate-relevant actions in this multilateral context. These findings thus raise compelling questions regarding not only what technical challenges but also what political dynamics help to explain these adherence patterns.

Finding II: Developing countries, very transparent, hardly transparent

With regard to transparency adherence patterns among developing countries, our analysis finds that the extent of participation of this group of countries in UNFCCC transparency arrangements is relatively low, especially for Least Developed Countries and Small Island Developing States, who are permitted discretion in the timing and scope of reporting.

Several more specific findings are worth mentioning:

First, seven out of a list of twenty developing countries with the largest greenhouse gas emissions (in 2017) had not submitted even one Biennial Update Report, as of February 2020 (i.e., more than four years after the suggested deadline). Also striking is that South Africa, which has consistently voiced support for UNFCCC transparency arrangements in international climate negotiations, shows relatively low adherence to transparency requirements over time.

Second, some developing country reports are assessed as having attained full (100%) adherence to certain transparency requirements, as per the methodology relied upon by UNFCCC teams of technical experts. This too raises various salient questions: what might 100% adherence signify? Does it signal adequate capacities in data availability and information generation within a country, with no need for further improvement? How meaningful is such an assessment; and are the most important categories of information being generated and shared?

Third, developing countries adhere more to reporting requirements relating to greenhouse gas inventories rather than mitigation actions, as do developed countries. Reporting requirements relating to adaptation actions and to financial support received are not mandatory, and therefore were excluded from our analysis of adherence here. Yet this signals an important question for these global arrangements, in terms of categories of information being prioritized herein.

Conclusion: Adherence patterns help ‘shine a light’ on the assumed role of transparency

The findings noted above all merit further empirical scrutiny. Our ‘Transparency Adherence Indices’ also lead us to advance an intriguing hypothesis, as we noted above: that a country exhibiting more climate ambition, both in terms of actions and intentions, may well perform better in adhering to transparency requirements. Instead of transparency stimulating greater ambition, greater ambition may result in greater adherence to transparency.

If so, does transparency follow rather than shape political developments? Continued research on this topic is very timely, given that the 2015 Paris Agreement calls for an ‘enhanced transparency framework’ to be implemented, starting in 2024. This is intended to build on lessons learned from engagement with current UNFCCC transparency arrangements. If so, the Adherence Indices we generate in our article provide vital context for assessing the continued relevance of ever-expanding UNFCCC climate transparency requirements. They shed light not only on what engagement looks like currently; but also raise the important question of what constitutes meaningful adherence in the first instance, and to realize what climate policy goals.

New research article on face-to-face account-giving in multilateral climate transparency processes

A recent article by Aarti Gupta, Sylvia Karlsson-Vinkhuyzen, Nila Kamil, Amy Ching and Nadia Bernaz in the journal Climate Policy analyses how novel, face-to-face, account-giving processes for developing countries, referred to as ‘Facilitative Sharing of Views’, are functioning within the United Nations Framework Convention on Climate Change (UNFCCC) and what these processes help to shed light on. It analyses the nature and scope of the ‘answerability’ being generated within these novel processes, including what state-to-state questioning and responses focus on, and what ‘performing’ accountability in this manner delivers within multilateral climate politics. The authors find that a limited number of countries actively question each other within the FSV process, with a primary focus on sharing information about the technical and institutional challenges of establishing domestic ‘measuring, reporting and verification’ systems and, to lesser extent, mitigation actions. Less attention is given to reporting on support. A key aim is to facilitate learning, both from the process and from each other. Much effort is expended on legitimizing the FSV process in anticipation of its continuation in adapted form under the 2015 Paris Agreement.

Here are their key policy insights:

  • We analyse developing country engagement in novel face-to-face account-giving processes under the UNFCCC
  • Analysis of four sessions of the ‘Facilitative Sharing of Views’ reveals a focus on horizontal peer-to-peer learning
  • States question each other more on GHG emission inventories and domestic MRV systems and less on mitigation and support
  • We find that limited time and capacity to engage, one-off questioning rather than a dialogue, and lack of recommended follow-up actions risks generating ‘ritualistic’ answerability
  • Such account-giving also intentionally sidesteps contentious issues such as responsibility for ambitious and fair climate action but may still help to build trust
  • Much effort is expended on ‘naming and praising’ participant countries and legitimizing the process

The article is fully open access and can be found here.

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:

New book on accountability mechanisms in International Development Financing

Susan Park, Professor of Global Governance at the University of Sydney, has just published a new book on the mechanisms by which multilateral development banks can be held accountable for their social and environmental impacts.

In ‘Environmental Recourse at the Multilateral Development Banks’, Professor Park outlines how international development financing has sometimes had “dramatic and irreversible effects” on local communities. In reaction to this, NGOs and environmental activists have called for ways of holding multilateral development banks accountable for these impacts. The book examines these so-called “international grievance mechanisms”, whether and how they are used, and what effects they have. Her results give a mixed picture:

While the book demonstrates how the processes work in a generally just manner, it also shows that the problem-solving function can only work if it is in the interests of claimants, the Bank, the government, and/or the project sponsor (for non-sovereign loans). This leads to a high rate of unsuccessful outcomes from communities attempting to engage directly with the Banks and project sponsors.

Susan Park, Can We Uphold Environmental Rights in International Development?

For more detailed summary of this important publication on the transparency and accountability of actions in international development finance, please see Professor Park’s Blogpost on the subject. The book itself is freely accessible online until November 24th at Cambridge Elements.