The world is preparing for the United Nations Framework Convention on Climate Change’s (UNFCCC’s) 31st Conference of the Parties (COP31) in November, which the COP31 Presidency has deemed the “COP of the Future.” But what is the future of the Paris Agreement without the compliance of countries with their obligations?

More than ten years after the adoption of the Paris Agreement, the UN climate process is finally fully working, moving from an era of foundational negotiations toward one of implementation.

The Paris Agreement has gone through its first full turn of its five-year ambition cycle, its essential rules are in place, its reporting frameworks have been established, and countries have had more than a decade to align national climate governance with the Agreement’s requirements. Ensuring that Parties comply with the obligations that make the Paris Agreement process effective, however, continued to be a fundamental challenge.

In 2025, the Paris Agreement Implementation and Compliance Committee (PAICC) found 208 Parties had failed to meet their mandatory procedural obligations, and, as of August 2026, roughly 59 cases are still pending.

For example, many Parties failed to meet the most recent submission deadline for nationally determined contributions (NDCs), biennial transparency reports (BTRs), and Article 9.5 Biennial Communications (Article 9.5 BCs).

Though compliance may not generate the same levels of attention as announcements of new climate targets or political commitments, it is crucial to the Paris Agreement’s success.

What is the PAICC?

The PAICC serves as the Paris Agreement’s implementation and compliance mechanism. Unlike the Kyoto Protocol’s compliance mechanism, the PAICC takes a facilitative and non-punitive approach to help Parties overcome challenges to meeting their obligations without imposing penalties. It does so by initiating “issues of consideration” in four scenarios:

1. Party self-referral
2. Party non-compliance with the submission of NDCs, BTRs, Article 9.5 BCs or participation in the facilitative multilateral consideration of progress
3. identification of significant and persistent inconsistencies
4. identification of systemic issues

Issues of consideration are investigated at bi- or tri-yearly meetings where Committee members hear presentations on the current state of compliance and convene with Parties in private. For example, PAICC initiated engagement with 171 non-compliant Parties in 2025 with respect to their NDCs. Throughout 2025 and 2026, PAICC communicated and supported the non-compliant Parties, aiding the submission of 106 NDCs. While 45 Parties have still not submitted NDCs, PAICC has increased compliance significantly through the facilitative process.

What Happened at PAICC-17?

The PAICC’s 17th meeting (PAICC-17), in June 2026, was open to the public and revealed new deliberations on criteria development for identifying significant and persistent inconsistencies and systemic issues.

• Significant and Persistent inconsistencies: Part of the Committee’s mandate is to investigate significant and persistent inconsistencies in reported data. To complete this mandate, the Committee must develop criteria identifying when an inconsistency is “significant and persistent” and thus requires PAICC engagement. Informing the identification of criteria, the Committee is building knowledge on how technical expert reviews (TERs) are conducted. PAICC engagement will improve and streamline the BTR review processes, increasing efficiency and data accuracy. Separately, at PAICC-17, the Committee considered deliberations regarding Article 6 on carbon markets for the first time. This work will support the robust and accurate reporting of Internationally Transferred Mitigation Outcomes (ITMOs).
• Systemic Issues: PAICC is also mandated to investigate issues of a systemic nature. Much like their work on inconsistencies, the Committee must first identify criteria. Still in the beginning stages of this process, PAICC members are compiling a list of challenges and constraints conveyed by Parties in their compliance communications. Further, at PAICC-17, members suggested quantitative measurements for whether an issue is systemic, such as: non-compliance in two consecutive NDCs, cross examining whether countries in certain regions/with similar national circumstances are communicating similar issues, or more simply looking at compliance regionally. However, much of this information is sensitive, and the Committee moved into closed session for most of the discussion.

Looking ahead:

The PAICC’s efforts to facilitate compliance are critical to ensuring that the minimum requirements of the Paris Agreement are fulfilled—particularly as the climate community gears up for the launch of the second global stocktake, which will assess collective progress towards the Paris Agreement’s long-term goals. When Parties comply with their mandated obligations, the Paris ambition cycle produces a clearer picture of global climate action both promised and taken that informs the road ahead.