Source: istock


Transparency of Action: Issues for COP 26

The enhanced transparency framework (ETF), and the flexibility it provides to developing countries in reporting and review, is a central feature of the Paris Agreement. Its effective implementation is essential to build trust and confidence in the regime.

Many of the modalities, procedures, and guidelines (MPGs) for the ETF were adopted at the UN Framework Convention on Climate Change (UNFCCC) climate conference, or COP24, in Katowice. However, Parties scheduled further work for COP26 on items necessary for the ETF to become fully operational in time for Parties to submit their first biennial transparency reports (BTRs) by 2024. The lack of progress in some of these items and the postponement of COP26 until 2021 have raised the following issues:

  • making progress on transparency in 2021 in the broader context of the Paris Agreement’s ambition cycle
  • flexibility in relation to the national inventory report tables that Parties will use in reporting their greenhouse gas inventories
  • the applicability of “structured summary” formats that report progress towards a Party’s nationally determined contribution (NDC).

Further delay has the potential to cause significant problems. Of particular concern is the limited time in which the Secretariat must design and operationalize the reporting and review system, including updating and providing training for the software that Parties may use to prepare their national greenhouse gas inventories. Parties, for their part, need clarity in the reporting requirements in order to develop or update their own domestic measurement, reporting, and verification systems.

In that context, reaching a successful conclusion on the ETF at COP26 is critical. Although the remaining work is highly technical, the following overarching considerations will be important in reaching success in Glasgow:

  • The relevant provisions of the Paris Agreement and the ETF’s MPGs are agreed and should not be reopened or renegotiated, and heads of delegation (HODs) will have an important role to guide their negotiators accordingly.
  • The mandates and MPGs are sufficiently detailed with respect to implementing flexibility.
  • The need for a process to address all remaining work under the Paris Rulebook in a way that results in a balanced and coherent outcome at COP26.
  • Reporting and review should involve a facilitative, iterative process that respects Parties’ capacities by providing flexibility as well as continuous capacity-building support.

Some of the key issues are explored in more detail below.

Mode of Work & Process

Given the volume of remaining work (for instance, Parties are currently discussing some thirteen common reporting tables [CRTs] for greenhouse gas inventories), it is critical that formal and informal settings are used effectively to make progress ahead of COP26. The mode of work must change in order to be able to make up for time lost due to COVID19, including by making effective use of virtual settings until in-person meetings are possible once again.

As such, the increased attention now being given to the issue of transparency is welcome. The COP25 and incoming COP26 Presidencies hosted their HODs consultation on transparency from April 28-29, 2021. And the Subsidiary Body for Scientific and Technological Advice (SBSTA) Chair hosted, from May 5-7, 2021, an informal technical workshop on: possible options for the CRT of the national greenhouse gas inventory; the common tabular format (CTF) of the structured summary; and possible options for the CTF of finance, technology, and capacity-building support, which will facilitate other work under this agenda item.

It is essential to make progress at the Subsidiary Bodies (SB) sessions, which will convene work virtually in 90-minute sessions across three time zones from May 31 to June 17, 2021. A new draft provisional agenda going into the SBs reflects mandates from 2020 and 2021, with some items deferred to the next in-person meeting. The SB Chairs will capture progress by preparing informal notes that may further inform discussion with the aim of reaching agreement at COP26.

Aside from the SBs, there is a critical need to create as much space as possible to facilitate the completion of technical work on remaining issues related to the specific ETF related mandates from the decision in Katowice (18/CMA1). In that regard, a robust process that avoids general discussions but rather focuses the work of experts on specific examples and proposals, is essential. Such a process could include:

  • encouraging further submissions from Parties with experts encouraged to exchange views on them
  • a further synthesis report on the basis of Party submissions to facilitate discussions
  • additional technical workshops to be organized following the SBs in order to narrow gaps ahead of COP26
  • an open-ended working group to continue work on ETF issues after the SBs in June.

 Flexibility and Applicability in Relation to National Inventory Reports

Flexibility in the implementation of the ETF is important for those developing countries that need it in light of their capacities. The MPGs set out specific options for flexibility in the CRTs for inventory reporting.

In order to make progress, technical experts could be instructed by HODs to push for agreement based on the comprehensive set of CRTs currently used by Annex I Parties, with the understanding that one set of tables does not mean that the same information is required from all Parties. Once agreed, consideration of the operationalization of flexibility could be undertaken, with HODS consulted as needed.

Furthermore, those flexibilities most relevant to an efficient review process could be considered first.

CTF for the Structured Summary

The structured summary, which requires Parties to report the information necessary to track progress in implementation and achievement of their NDCs, is a new feature of the reporting and review process for all Parties. Mandates in terms of the information to be provided are clear and can largely be converted into headings for a table. Given that countries are free to choose their NDCs as well as the indicators that will measure progress towards those targets, the CTF for the structured summary will need to accommodate the range of current and future NDCs.

The Structured Summary and the Information to be Provided on Cooperative Approaches

The structured summary requires information to be provided on cooperative approaches under Article 6 of the Paris Agreement. Of particular relevance is the treatment of corresponding adjustments.

There is, therefore, a need for close coordination between the Article 13 and Article 6 negotiations, and neither should be viewed in isolation. HODs in particular have a role in ensuring that the issue of linkage between Article 13 and Article 6 is carefully managed and that political sensitivities are identified and taken into account.

Some Parties are of the view that Article 13 negotiators should progress as far as possible independently of, and without prejudice to, the Article 6 negotiations. According to this view, discussions on the structured summary should not be delayed until Article 6 is resolved, and since there is sufficient guidance on the type of information to be provided on cooperative approaches, which is minimal, there should be enough to set out headings on the CTF or to use placeholders to allow for Article 6 outcomes to be inserted when they are ready.

Other Parties are of the view that Article 6 and Article 13 discussions need to advance as much as possible in parallel, with Article 13 not advancing on its own out of concern that it could pre-judge the outcome of the Article 6 work. Accordingly, work on Article 6 would need to be completed before the structured summary could be finalized, since Parties would need guidance on corresponding adjustments. If agreement on the information required under paragraph 77(d) of the MPGs were to be deferred until all other issues were decided, the potential consequence would be that the remaining technical work for Article 13 would not be adopted if agreement on Article 6 could not be reached at COP26.

Capacity-building & Learning by Doing

There is a range of capacities and experience among developing countries regarding reporting and review, including the use of reporting software to produce CRTs. Article 13 clearly states that capacity-building will be provided for developing countries on a continuous basis. In that context, capacity building is critical to help developing countries that need it in their transition to the new ETF, and to improve over time. Throughout the negotiations on the ETF and its MPGs, Parties frequently emphasized that developing countries cannot be expected to report perfectly the first time and that improvements would come over time with gained experience. This assurance needs repeating.

The Global Environment Facility must provide timely support for developing countries to produce their BTRs.


HODs should allow their technical experts to make as much progress as possible in advance of COP26, and opportunities should be created to facilitate this. However, there will likely come a time in Glasgow when HODs, or even Ministers, will have to resolve outstanding issues. Blockages at this stage are likely not to be only technical, but rather have a political dimension, and will relate to a lesser or greater extent to the balance of the overall COP26 outcome. Therefore, it is important that HODs are familiar with the issues, such that they understand the remaining room to maneuver towards agreement by time they arrive in Glasgow. In other words, HODs will need to prepare well for success in Glasgow.

As developing countries anticipate engaging in new and unfamiliar processes, it would be helpful if, ahead of Glasgow, the UNFCCC Secretariat could continue to highlight relevant available capacity building resources, and further assurances are provided by developed countries that support will continue to be delivered. And developed countries could helpfully repeat assurances given before the run up to Paris, and in agreeing the subsequent MPGs, that developing countries are not expected to report perfectly the first time.