Cop25 Key Outcomes: January 2020

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COP25 KEY OUTCOMES
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COP25 KEY OUTCOMES

Humanity no longer faces climate change. We face a “climate emergency”.
25TH
CONFERENCE 2019 has become the year that the world really woke up to the existential threat
OF PARTIES TO of climate change, and the narrative was updated to signal urgency. The global
THE UNFCCC response to the threat, however, was still found lacking. Civil society participants,
commentators, and even the UN Secretary-General were disappointed with the
results of the Climate Change Conference in Madrid, also known as the 25th
MADRID, SPAIN Conference of Parties (COP25) to the UN Framework Convention on Climate Change
(UNFCCC), in December 2019. “The international community lost an important
opportunity to show increased ambition on mitigation, adaptation, and finance to
2-15 DECEMBER
tackle the climate crisis,” António Guterres said in a statement.
2019
The crunch issues at the Conference – much higher climate ambition to meet the
Written by
Anju Sharma
goals of the Paris Agreement, finance for the loss and damage caused by climate
Axel Michaelowa impacts, a fail-safe market mechanism that does not compromise environmental
Aglaja Espelage integrity, and credible financial contributions to enable action in developing
Jennifer Allan
countries – proved too difficult to resolve within the high-pressure, time-deficient
Benito Müller
confines of a COP, despite a two-day extension and the resilience and staying power
With comments and quotes of seasoned diplomats.
from the ecbi network of
UNFCCC negotiators
This was not only because some of the issues were too technical. The political will
Photos by to treat them with the urgency that they deserve was clearly missing. Tactics to
IISD/ENB | Kiara Worth delay progress and prioritise narrow self-interest, increasingly familiar to COP
observers, were fully on display. The conference “seems to have turned into some
kind of opportunity for countries to negotiate loopholes and to avoid raising their
JANUARY 2020 ambition,” noted climate activist Greta Thunberg, with acuity.
European Capacity Building Initiative

www.ecbi.org
While such tactics are not foreign to the climate negotiations, and expectations are
generally tempered as a result, COP25 even failed to meet its own modest ambitions.
“Rule 16” in the draft rules of procedure of the UNFCCC, which states that an agenda item
that cannot be completed at a conference will automatically roll over to the next session,
proved to be a particularly popular outcome for many of the issues that were discussed.
The broader global context of rising nationalism continued to play out in the
background. It is the sign of the times that the Chile Madrid Time for Action (CMTA)
Decision adopted by COP25 begins by recognising the important role of multilateralism,
which could be taken for granted not so long ago, and has to emphasise the important
role of science in tackling climate change. In Madrid, as in Katowice in 2018, there
were once again strong views expressed on whether the two new special reports of the
Intergovernmental Panel on Climate Change (IPCC) should be “welcomed” or merely
“noted”. In the end, the Decision “expresses its appreciation and gratitude to the IPCC
and the scientific community for providing the 2019 Special Reports, which reflect the best
available science”. Admittedly, this is an improvement in the recognition of the work of the
IPCC from last year, when only the “timely completion” of the 1.5°C report was welcomed.
The CMTA also reiterates the importance a “just transition of the workforce”. This notion,
also included in the preamble of the Paris Agreement, appeared to be an imperative for
Chile in the light of social unrest back home. Incidents like the unrest in Chile and the
gilet jaune protests in France in November 2018 highlight how important it is to ensure
that the “transformational change” needed to address climate change is carried out on a
solid foundation of social dialogue, inclusion, and equity.
The biggest disappointment from the Conference was perhaps the lack of clear and
strong language telling countries what is expected of them next: significant leaps in
ambition in the first round of Nationally Determined Contributions (NDCs) whose
implementation begins in 2020, to reduce the “ambition gap” between their actions and
the action needed to limit global average temperature rise to 1.5°C (or indeed, even 2°C).
CONTENTS
The inability to finalise the remaining elements of the Paris Agreement Work
Programme (PAWP) comes a close second. Parties were unable to agree on the rules for
AMBITION the so called “cooperative approaches” under Article 6 of the Paris Agreement. Without
PAWP these rules, countries that want to use cooperative approaches to significantly and
credibly ramp up NDC ambition will not be able to do so. This also delays potential
article 6
funding for adaptation that is expected to accrue from an adaptation levy on some
common time frames forms of cooperative approaches.
transparency
adaptation communications Another essential part of the PAWP that could not be agreed was that of a common time
frame for NDCs of all countries. Despite the repeated denial of a link between common
capacity building
time frames and ambition by many countries, this could in fact impede overall ambition,
WIM particularly in the crucial ten-year period up to 2030. It could also impede a clear and
GENDER accurate assessment of global progress towards the goals of the Paris Agreement in the
first global stocktake in 2023.
FINANCE
ADAPTATION Differences also persisted on the detailed templates for the “enhanced transparency
framework” that will track implementation of the NDCs. Quite a lot of technical work
READING THE RUNES still remains to be done on the transparency framework (although once again it was not
ABBREVIATIONS only technical considerations that blocked progress in this area at COP25), and with no
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intersessional work planned, it even looks unlikely that the work will be completed at
COP26.
Only incremental steps were taken on other, non-PAWP, issues under the COP and
Conference of the Parties serving as the Meeting of the Parties to the Paris Agreement
(CMA) that need urgent resolution rather than further delay. While the review of the
Warsaw International Mechanism (WIM) for Loss and Damage was completed, the
issues of governance of the WIM, and more critically, of finance for loss and damage due
to climate change, remained unresolved.
The larger question of climate finance also proved controversial, with disagreements on,
among other things: whether the discussions on long-term finance should continue post-
2020; whether the Standing Committee on Finance (SCF) should work on a “common”
definition of climate finance, the scope of its needs assessment report, and whether it should
prepare a synthesis report on the US$ 100 long-term goal; the rules of procedure of the
Adaptation Fund; and on “privileges and immunities” for the Green Climate Fund (GCF).
On gender, an “enhanced five-year Lima work programme on gender and its gender
action plan” was agreed, but only after efforts by the COP Presidency to resolve
The Paris Decision
differences, including on whether respecting human rights should be “in light of
noted that the current national circumstances”, and tracking of progress was needed.
NDCs do not achieve
the 2°C goal, much A related issue that ostensibly flew under the radar was a proposal to commence work
less the 1.5°C target. on a code of ethical conduct. A draft code was proposed by a small drafting group
That is why it calls in the UNFCCC Bureau, to ensure that all participants attending COP behave in an
on Parties to provide ethical manner and to allow for those who are subject to harassment or other unethical
behaviour to have a formal process of redress. It was introduced briefly by Tuvalu in the
revised, enhanced, and
discussions on the CMTA Decision, but despite warmly welcoming the initiative in the
more ambitious NDCs Bureau, the COP President struggled to find a means of advancing the issue within the
by March 2020. At the Decision text and it fell through the cracks.
very least, COP25 should
have made an explicit
call for this and provided OVERALL AMBITION
a mechanism for
assessing the effect of The Madrid Conference took place a little more than three months before the March
the revised NDCs so that 2020 deadline for the submission of NDCs, before the implementation of the Paris
Agreement begins. “2020 is only a few weeks away – the year when we must see more
informed discussions
climate ambition reflected in new and revised NDCs. Without them, our window of
can take place at opportunity closes,” warned UNFCCC Executive Secretary Patricia Espinosa at the
COP26.This was a major opening of the high-level segment of COP25.
disappointment.
The current gap between the ambition reflected in NDCs, and the action needed to
carlos fuller belize achieve the Paris Agreement goals is “large”, according to the Emissions Gap Report 2019
of the UN Environment Programme. Countries must increase their NDC ambitions
threefold to achieve the 2°C goal and more than fivefold to achieve the 1.5°C aspiration.
This must happen in the NDCs whose implementation begins in 2020. “Given the time
lag between policy decisions and associated emission reductions, waiting until 2025 to strengthen
NDCs will be too late to close the large 2030 emissions gap,” according to the report
During the Madrid Conference, the Least Developed Countries (LDCs), Alliance of Small
Island States (AOSIS), Independent Association of Latin America and the Caribbean

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(AILAC) and several other countries wanted an explicit call for countries to update their
NDCs in 2020 and to increase ambition in the CMTA Decision under the CMA, which
sought to present a common vision for the future.
However, this was opposed by China, India, and Brazil, among others, who argued that the
decision to update and/or enhance should be made by countries in the bottom-up regime
of the Paris Agreement. The reference to updating and enhancing 2020 NDCs was removed
from the penultimate draft of the decision, prompting a response from the High Ambition
Coalition in a press conference. “The framing of ambition in the current text remains
unsatisfactory. It puts us at the risk of leaving here without a clear call to enhance ambition
next year in line with the best available science,” said Tina Eonemto Stege, Climate Envoy of
the Marshall Islands. The language was made slightly stronger in the final CMTA Decision,
although it still fails to include a clear requirement to raise ambition. It:
● Re-emphasises the urgent need to address the emissions gap;

● Encourages Parties to use the opportunity in 2020 to reflect the highest possible
ambition to achieve the Paris Agreement goals;
● Reminds Parties that each NDC must represent a progression and reflect highest
possible ambition; and
● Reminds them of paragraphs (§) 23 and 24 in Decision 1/CP.21 (requesting
Parties with a five-year time frame to communicate a new NDC by 2020, and for
Parties with a 10-year time frame to communicate or update their NDC by 2020).
It urges them to consider the emissions gap and reflect their highest possible
ambition when responding to this request.
Pre-2020 ambition
Why some countries opposed references to updating and enhancing NDCs
One reason why countries like India, China, and Brazil opposed calls for enhancing
ambition in the NDCs was that they first wanted to take stock of the action taken by
developed countries in the pre-2020 period. They fear that in the post-2020 period,
they will be expected to fill the emissions gap largely created by the historic inaction of
developed countries. (Other reasons have also been ascribed to their reluctance, such
as the withdrawal of the US from the Paris Agreement, which could mean that post-
2020 action by developed countries could also fall short). Pre-2020 action includes both
mitigation pledges (under the Cancún pledges and the Doha Amendment to the Kyoto
Protocol – the latter has not yet entered into force even though it ends in 2020), and
climate finance pledges.
“[2020] is the year in which Parties’ pre-2020 actions under the Convention are supposed
to conclude and lay the foundation for future climate actions for Parties to the Paris
Agreement,” the State of Palestine said in an opening statement on behalf of the G77 and
China. “However, developed countries’ fulfilment of their long-standing commitments for
ambitious climate actions under the Convention, including reducing their own emissions
and the provision of support to developing countries, has been thus far insufficient”.
The Like-Minded Developing Countries (LMDCs), Brazil, India, South Africa, China
(BASIC), Argentina, Brazil, Uruguay (ABU), African Group, and the Arab Group called
for a two-year work programme on pre-2020 implementation and ambition, to identify
the progress and gaps on mitigation, adaptation, finance, technology development and
transfer, and capacity building of the pre-2020 commitments by developed countries,

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and to make arrangements to close the gap.1 They also wanted to extend discussions on
long-term finance item beyond 2020 and a status report on the US$ 100 billion pledge
by developed countries (see finance section). This was opposed by developed countries,
including the EU, who called for a focus on the future, rather than the past.
In the end, in the CMTA Decision adopted by COP25, Parties decided to hold a round
table among Parties and non-Party stakeholders on pre-2020 implementation and
ambition at COP26 in Glasgow, in 2020. Submissions are invited by September 2020
to inform the round table – these will be summarised by the secretariat. The CMTA
Decision adopted under the Conference of the Parties serving as the meeting of the
Parties to the Kyoto Protocol (CMP) stresses the urgency of delivering on the pre-2020
commitments under the Kyoto Protocol, and underscores the urgent need for the Doha
Amendment to enter into force. Agreement was not possible on how discussions on
long-term finance under the Convention will continue after 2020, particularly in a
With the Paris context where the US will no longer be Party to the Paris Agreement, and on the US$
Agreement and its 100 billion status report. These issues will continue to be discussed in 2020.
rulebook mostly in
The issue of assessing pre-2020 action also arose in the context of the scope of the “periodic
place, the negotiations
review” of the long-term global goal of the UNFCCC, to achieve stabilisation of GHG
should adjust to concentrations in the atmosphere at a level that would prevent dangerous anthropogenic
provide operational interference with the climate system (UNFCCC Article 2). The first such review took place
and functional between 2013-2015, following which the long-term goal was updated to reflect the Paris
guidance to keep the Agreement goal to limit warning to well below 2°C and pursue efforts to stay below 1.5°C. At
momentum going. COP25, Parties first disagreed on whether a second periodic review should take place at all.
Once it was agreed that it should, disagreement arose on its mandate – developing countries
The COP in Madrid
wanted it to include a review of pre-2020 action by developed countries. In the end, while
showed an attempt by
it was agreed that the second review will begin in the second half of 2020 and conclude in
many to undermine the 2022, no reference is made to pre-2020 action. It was also decided that the review will not
environmental integrity result in an alteration or redefinition of the long-term global goal.
of an Agreement
that should already
be driving action COMPLETION OF THE PARIS AGREEMENT WORK
and ambition on the PROGRAMME
ground.
Four issues from the PAWP still remained to be resolved after Katowice: the rules for
alejandra lopez Article 6 of the Agreement; common time frames; elements of the Agreement’s enhanced
ailac transparency framework; and the initial institutional arrangements for capacity building.
Article 6
Article 6 of the Paris Agreement offers Parties three modalities of voluntary cooperation
in the implementation of their NDCs:
● Bilateral or multilateral cooperative approaches, where Parties transfer

mitigation outcomes internationally to facilitate the achievement of their NDCs
(Article 6.2). The CMA is mandated to adopt guidance to regulate cooperation,
reporting requirements, and accounting for “internationally transferred
mitigation outcomes” (ITMOs) through so-called “corresponding adjustments”.
● A crediting mechanism under the auspices of the Paris Agreement, where
emission reduction credits will be issued for activities authorised by Parties
1. Draft text on Decision 1/CP.25, 13 December 2019 6 am

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(Article 6.4), and can then be acquired by other Parties. The CMA is asked to
adopt the rules, modalities, and procedures for this mechanism.
● A framework to promote non-market based approaches (Article 6.8). The
CMA will adopt a work programme to operationalise this framework.
Consensus was not possible on these three issues in 2018 at COP24 in Katowice, and
so the rules for Article 6 were not adopted in conjunction with the rest of the so-called
“Paris Agreement rulebook”. Instead, the rules were to be finalised at COP25. (For more
details on the key crunch issues that remained to be resolved before COP25, read this
ecbi policy brief). This proved impossible once again, and the adoption of the “Article 6
rulebook” has now been deferred to COP26 in Glasgow.
There was slow but steady progress on many issues during the first week of COP25. The
Chair of the Subsidiary Body on Scientific and Technological Advice (SBSTA) conducted
meetings with the heads of delegations early on, focusing on three crunch issues:
“corresponding adjustments”, to ensure that only one country claims credit for emission
cuts and there is no double counting; an adaptation levy on transactions under Article
6.2; and the transition of activities and credits from the Clean Development Mechanism
(CDM) of the Kyoto Protocol to Article 6 of the Paris Agreement. In addition, the
co-facilitators of the discussions arranged “informal-informal” meetings to discuss
specific outstanding issues. Despite these efforts, the texts forwarded to the ministerial
negotiations on Articles 6.2 and 6.4 at the end of the first week contained many brackets.
In the second week, the negotiations suffered from an unclear process, and some
observers complained about the lack of high-level engagement by the Presidency
and the delay in bringing all Parties to the negotiating table. Instead, the Presidency
conducted bilateral consultations with different groups for several days, while non-
facilitated technical discussions on selected issues continued. In the final days of the
Conference, ministerial consultations took place on a few outstanding issues in different
formats. The Presidency then issued three texts for each of the three components of
Article 6 in an effort to break the deadlock – first on Friday, 13 December, then on
Saturday, and finally on Sunday.2
The texts published on Saturday, in particular, had several compromises proposed on

the adaptation levy under Article 6.2; the achievement of “overall mitigation on global
emissions” (OMGE) to ensure a net benefit for the atmosphere; and concrete dates and
timelines for a transition process from the CDM to the Article 6.4 mechanism. However,
no agreement could be found. The latest, Sunday iteration of the Presidency texts
then proposed deferring difficult issues to a later stage, but this was unacceptable to a
number of Parties (including Brazil, India, and the African Group) who did not think the
final Presidency text reflected all the positions expressed through the two weeks of the COP.
This could have been because of the hasty iterations of text in a very short period of time.
Despite the brief, procedural nature of the outcome adopted in the end, stating that
negotiations would continue during the June 2020 session on the basis of the three
Presidency texts of 13-15 December, progress was achieved on a number of issues.
2. Texts released on Friday: on Article 6.2, Article 6.4, and Article 6.8. Texts released on Saturday, on Article
6.2, Article 6.4, and Article 6.8. Texts released on Sunday, on Article 6.2, Article 6.4, and Article 6.8.

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Article 6.2: Guidelines on cooperative approaches
On Article 6.2, Parties worked on compromises to account for different types of
NDCs. This included differentiating accounting approaches for NDCs with multi-year
mitigation trajectories and NDCs with a mitigation target for a single year, where
averaging and trajectory-based approaches will be applied.
Parties also developed more detailed provisions on how to account for ITMOs that are
expressed in non-greenhouse gas (GHG) metrics. The final iteration of the Presidency
text proposed that corresponding adjustments will be applicable to all types of transfers,
irrespective of whether the ITMO was achieved within or outside the scope of the NDC,
whether the ITMO is used towards another Party’s NDC, or whether it is used for other
international mitigation purposes, such as the Carbon Offsetting and Reduction Scheme
for International Aviation (CORSIA).
The reporting and review procedures for Article 6.2 were clarified, and the coherence
of the chapters on reporting, review, and recording and tracking was improved. As
a compromise on the application of an adaptation levy on Article 6.2 transactions
(opposed by developed countries), it was proposed that ITMO buyers be “strongly
encouraged” to contribute to adaptation funding at a level “commensurate” to the share
of proceeds levied under Article 6.4.
We are disappointed Article 6.4: Rules, modalities, and procedures

that it was not possible Parties made progress on a proposed work programme for SBSTA and on the Article
to finalise the rules for 6.4 Supervisory Body. On corresponding adjustments for activities “outside” an NDC, a
Article 6 in Madrid, but it grace period of five years was proposed (a deviation from the accounting rules proposed
is better to postpone their under Article 6.2).
adoption than to seek
Significant progress was achieved in developing a compromise for the review of CDM
to satisfy the concerns
methodologies and their preliminary use in Article 6.4 activities in a transitional period;
of some countries and and for the re-registration of CDM activities after an eligibility check and renewed host
stakeholders at the country approval. It was proposed that CDM credits from activities registered after a
expense of the planet and cut-off date be allowed for a transition period, and only be allowed to be used towards
vulnerable populations. NDCs before a defined date.
el hadji mbaye diagne The final iteration of the text also presented clear compromise proposals on the “share
senegal of proceeds” for adaptation (at a level of 2% of credits). It narrowed down the options
for operationalising OMGE to a mandatory cancellation (with a minimum of 2%,
increasing over time), thereby discarding the option of operationalising OMGE through
conservative baselines that was still present in the version before. While emissions
“avoidance” (for instance, through forest protection) was excluded, “removals” (through
afforestation and reforestation and other negative emissions technologies) were included.
Options to account for transfers of mitigation outcomes expressed in non-GHG metrics

(for instance, megawatts or megawatt hours in the context of renewable energy instead
of CO2e) were also fleshed out, introduced in the text, and included in a follow-up work
programme. This was a key issue for the LMDCs in particular.

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Article 6.8: Work programme on non-market approaches
The negotiations on the Article 6.8 work programme progressed well – only a few
contentious issues remained after COP24. Bolivia, the strongest supporter of non-
market approaches, particularly of institutionalising the work programme and
facilitating join mitigation and adaptation activities, was absent from COP25. The final
iteration of the text proposes the establishment of a Non-Market Approaches (NMA)
Forum under the auspices of the chairs of the Subsidiary Bodies (SBs). The SBs will
consider the need for further institutional arrangements after a review of the work
programme in 2024.
The text also proposes tasking the NMA Forum to develop a schedule for the
implementation of the work programme, and inviting submissions on its priorities.
According to the text, the work programme would be implemented through workshops,
meetings with stakeholders and experts, the elaboration of technical papers, and in
coordination with other relevant ongoing processes under the UNFCCC. Activities under
the work programme will aim to develop and implement tools for the facilitation of
NMAs, and identify and share relevant information on them.
Deal breakers
This section summarises the key issues that proved to be deal-breakers in the final
rounds of informal Article 6 negotiations at COP25.
Article 6.2: Parties were unable to agree on the adaptation levy, and on OMGE. The
African Group, supported by many developing countries, demanded a mandatory
contribution to adaptation finance. This was strongly opposed by the US and many
other developed countries, though they were willing to accept a strong encouragement
to deliver adaptation finance at a scale commensurate with the funds levied under the
Article 6.4 mechanism. The issue of using surplus Kyoto units held in reserve – for
instance by Australia – to achieve NDCs in case of an eventual shortfall was also highly
contentious, though it was not discussed in detail in the negotiations.
Article 6.4: The Article 6.4 text proved to be the most contentious during the final
hours of negotiation. The question of whether Article 6.2 guidance should apply to
mitigation activities “outside” (or not included in) an NDC was a central controversy.
Parties were unable to agree on a common understanding of what “outside” an NDC
means, and what NDC progress is to be tracked against. While most countries refer to
“sectors and gases” that are included in an NDC and the measuring of progress against
GHG inventories from these sectors and gases, Brazil understands the NDC to be a
compilation of policies and measures. In this context, Brazil insisted on an exemption
from accounting for activities that it considers “additional” to government pledges
and thereby “outside” of its NDC. The delegation proposed compromise language to
accommodate different understandings of “outside” an NDC, which was not acceptable
to other Parties. In addition, there is no agreement on whether or not accounting for
action "outside" the NDC is required.
Another highly contentious issue was the use of pre-2020 CDM credits in Article
6. Brazil, India, and China rejected compromise proposals by the US and Japan to
introduce cut-off dates and limit eligible units to projects or programmes registered
after 2015 or 2016. Others (including the African Group, AILAC, AOSIS, LDCs, and
the EU) opposed any transition of units. They were unwilling to agree on earlier cut-

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off dates. Deferral of a decision on this issue to a later date was dismissed by Parties
supporting and opposing a transition.
The period in which pre-2020 CDM credits can be used towards NDCs was also
controversial. The second iteration of the Presidency text had proposed that all CDM
credits would have to be used by 2023, but some countries demanded that use should be
allowed for the complete first NDC implementation period, until 2030. The final iteration
of the text proposed deferring the discussion to 2020, but this was also not acceptable.
A further suggestion by the Presidency to put all non-transferable CDM credits into a
reserve account that can be accessed in future if the need arises was also rejected.
Another highly contentious and very technical issue was the specification of approaches
to set crediting baselines and determine the additionality of Article 6.4 activities. The
Presidency text proposed deferring this discussion as well, while a list of key principles
for methodologies was retained in an annex (related to transparency, conservativeness in
assumptions, link to NDCs, and ambition, among others). The deletion of a specific rule on
additionality testing and baseline methodology approaches dissatisfied several Parties.
COP25 has been seen by
many as a failure, buta Another issue that received significant media and civil society attention was the protection
lot of progress was made and promotion of human rights, and social and environmental safeguards in market-based
ina number of technical cooperation under Article 6 as a whole. Though several countries supported strengthened
negotiations, providing language in contact group meetings and plenary sessions, the issue was not discussed in
detail in informal negotiations, and the language in the draft texts remains weak.
clarity andtaking us
closer tooutcomes.
Future outlook
annela anger-kraavi Parties will now have to agree on a new consolidated text during the next negotiating
estonia session in June 2020. Although the last two iterations of the text significantly narrowed
down the options on the table, it is likely that a larger number of issues will be reopened
by Parties during this consolidation process. This happened after COP24, where there
was a similar situation and two texts were forwarded to SBSTA50. “If the text emanating
from COP25 can be used as the sole basis for further deliberations, then the Article 6
negotiations can be successfully concluded at COP26 in Glasgow,” says Carlos Fuller,
negotiator from Belize. “If time is spent debating the status of texts, then agreement
may not be possible even then.”
However, given the fact that the negotiations advanced significantly during COP25,
and many technical issues could be resolved to the satisfaction of most Parties, there
is hope that a number of the compromises won’t be revoked, and Parties can agree
quickly on a consolidated negotiation text at the next SB session. They can then focus on
outstanding (and mostly) political questions at COP26.
Discussions will most likely continue on the transition from the CDM; accounting for
activities “outside” NDCs; the metrics for transfers; and accounting for different types of
NDCs. The adaptation levy for Article 6.2 and OMGE for both mechanisms will continue
to be debated. Issues that completely fell through the cracks in the latest versions of
texts, such as the need for further safeguards and limits to international transfers, may
be brought up again.
While many expressed frustration at the lack of agreement on Article 6 at COP26,

others were relieved that a “bad deal” was avoided. In the final plenary, the EU and other
groups noted that market-based cooperation under Article 6.2 could go ahead in the

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absence of an Article 6 rulebook, while other Parties (including Brazil) insist that Article
6 is a package deal, and Article 6.4 and 6.8 need to be agreed before Article 6.2 can take
effect. In an interview, James Shaw, Minister for Climate Change, New Zealand, even
mused that putting the Article 6 negotiations on hold for a couple of years would be a
good idea, as compromise appears out of reach.
Meanwhile, nine countries, led by Costa Rica and Switzerland, launched the San José
Principles on 14 December 2019. The Principles include eleven criteria to ensure market-
based cooperation with “high integrity”, including through not using pre-2020 CDM credits,
corresponding adjustments for all transfers, a contribution to OMGE, and transparent
reporting. A further 22 countries signed on to the Principles within 24 hours, mostly from
AILAC, AOSIS, and the EU (with no signatures from Asia, Africa, or North America). It
remains to be seen if the Principles mark the debut of a new “club” in international carbon
markets, and what the implications of such a club will be on COP26 negotiations.
Common Time Frames

Another lost opportunity to complete the Paris ambition mechanism
A key element of the Paris rulebook that still remains to be resolved is the issue of
“common time frames”. The importance of this issue if often underestimated – it is
one (if not the only) way to create sufficient clarity and complete the Paris “ambition
mechanism”. It was decided, at the Paris Conference, that the CMA “shall consider”
common time frames for NDCs at its first session. Although this issue has been discussed
under the Subsidiary Body for Implementation (SBI) since 2017, the only progress made
so far was in Decision 6/CMA.1 at COP24, in Katowice in 2018, that “Parties shall apply
common time frames to their nationally determined contributions to be implemented from 2031
onward”. They could not agree on what those time frames would be.
Common time frames were discussed at the Heads of Delegation meeting in Santiago de
Chile in August 2019, indicating that the Presidency considered this a critical element
for an “ambition COP”. Indeed, at COP25, several countries drew explicit links between
common time frames and ambition, from AOSIS and LDCs to Brazil and the EU. It was
rather surprising, therefore, that the topic was given only two hours of negotiating time
in the SBI timetable during COP25. It was clearly not possible to make significant progress
in that time, or the small amount of additional time that was subsequently provided.
At COP25, one of the major disputes was whether countries should “update” the
ambition in their initial NDCs by COP26, five years after they were communicated, in
light of new developments over this period. Countries argued on whether §23 and §24
of Decision 1/CP.21, two defining components of the Paris ambition mechanism, are
sufficient to mandate a 2020 update. The conclusion was that the two paragraphs are
not sufficiently clear on the issue. In the end, it was not even possible to decide on a
deadline for a decision. The issue was rolled over to the next SBI session in June 2020,
and the SBI Chair suggested discarding the COP25 note on options to make a fresh start.
The SBI discussions at COP25 did, however, indicate a significant change in mood on the
issue among Parties compared to Katowice. In Katowice, there was no urgency attached
to arriving at a decision. In Madrid, the procrastinators3 were significantly outnumbered
3. According to the NGO Newsletter ECO on 7 December: “Canada and Australia suggested the issue doesn’t need
to be decided until 2023, and the US further suggested the issue needn’t be discussed again until 2022. The US was
outdone though by, good friend of climate action, Saudi Arabia who suggested that the issue not even be discussed

www.ecbi.org 10
by Parties calling for a decision to be taken as soon as possible. A number of Parties and
groups, including LDCs, the African Group, and the Environmental Integrity Group
(EIG), also agreed that the end-points of NDCs should be spaced at five-yearly intervals
rather than longer time frames (to avoid the risk of locking in low ambition for too long,
and to align NDCs with the five-year cycle of the global stocktake); and communicated
in a 5+5 pattern, as suggested in what has become known as the Dynamic Contribution
Cycle. There was considerable frustration about the lack of progress on this issue at
COP25, leading to a formal request by Brazil in the SBI plenary that more time be allocated
to this agenda item in future sessions, with a view to coming to a decision in Glasgow.
Civil society was also more vociferous in voicing their dismay on the lack of progress
on this issue. In an article entitled C’mon!!! Do we really Need 5 Years to Decide on 5
Year Common Time Frames?, non-government representatives asked, with incredulity,
whether those asking for more time were “missing the sad irony of asking for more time” in
light of the urgency for climate action.
Transparency
Chile did its best to
At the Madrid Conference, SBSTA was expected to continue work on the remaining
steer a meaningful elements of the Paris Agreement’s enhanced transparency framework, including:
outcome at COP25, formulating common reporting tables (CRTs) and common tabular formats (CTFs) that
but it was outgunned Parties must use in reporting information; agreeing the outlines of biennial transparency
by the negotiating reports (BTR), national inventory reports (NIRs), and technical expert review (TER)
might of Brazil and reports; and designing a training programme for the technical experts in the TER process.
others. It also lacked These elements are to be adopted by CMA3 at COP26 in Glasgow, in 2020. The first BTRs
and NIRs (if submitted as a stand-alone report) are then due by 31 December 2024.
the presiding authority
that a Presidency has The modalities, procedures, and guidelines (MPGs) for the enhanced transparency
when hosting a COP framework were agreed in Katowice, with flexibility provisions for those countries
in its own country.The that need it. It was also agreed that while the application of this flexibility will be self-
formal withdrawal of determined by countries, they should clearly indicate the provision to which flexibility
the US from the Paris is applied, clarify capacity constraints, and provide estimated time frames by which
Agreement was a major the constraints will be addressed. The operationalisation of this flexibility, and the
reconciliation of common reporting standards with the nationally determined nature of
contributing factor
NDCs, were major cross-cutting issues for all sub-items on the transparency agenda in
in downgrading the the Madrid discussions.
outcomes in Madrid.
There was a pervading Common Reporting Tables
sense of 'why should we On CRTs for NIRs, Parties discussed which of the tables that are currently used for
take strong action if the reporting under the UNFCCC can be adapted for the MPGs. Some developing countries
biggest polluter in the opposed the use of existing Common Reporting Format tables used by Annex I Parties,
world has walked away while others rejected making the use of CRTs mandatory. On operationalising flexibility,
from the process'. the options ranged from having specific notation keys, colour codes, footnotes, or
summary tables where flexibility was applied, to modifying tables as a whole or even
ian fry tuvalu deleting columns and rows where information cannot be provided. Agreement on CRTs,
and their harmonisation, will impact the ability to produce summary tables on NDC
progress and allow for technical reviews. While the discussions are very technical, they
will have a significant impact on the transparency of Paris Agreement implementation
Parties also discussed available and applicable software tools that could help reduce
reporting burdens.
until 2023. Miraculously, the EU is no longer the ones kicking this can the furthest down the road.”

www.ecbi.org 11
Common Tabular Formats
Parties discussed how to accommodate different types of NDCs in the CTFs to track
progress in NDC implementation, and how to reflect their country-driven nature in
common tables. The format of the structured summary of NDCs was also subject to
debate. This structured summary is a sensitive topic because:
● It defines how much detail Parties are ultimately willing to provide on whether
they are meeting their NDC targets.
● It includes information on the use of Article 6 cooperative approaches, while
negotiations on Article 6 are still ongoing.
There was consensus that the existing reporting tables under the UNFCCC are a good
starting point for discussion for the CTFs for support provided and mobilised, and for
support needed and received. Parties discussed how to differentiate and disaggregate
information on climate finance, technology transfer, and capacity building; between
mitigation and adaptation; and whether to include information on finance provided
and received for loss and damage. They discussed how to include information on the
definitions, assumptions, and methodologies used to estimate reported figures; and how
to report both support needed and received in the same CTFs.
Outlines of BTRs, NIRs, and TER report

Parties discussed if flexibility provisions should be addressed in stand-alone chapters in
these reports, and/or within different chapters. There was no consensus on whether an
executive summary should be mandatory for NIRs.
Training programme for TER experts

The role of the Consultative Group of Experts (CGE) in developing a training programme
for the technical experts participating in the review process was considered. (This
discussion was partly responsible for stalling discussions on the terms of reference for
the CGE, as it shifts toward supporting reporting under the Paris Agreement). Details of
the programme, including the number and the subject of the courses that reviewers will
have to undertake, were also discussed.
Parties were unable to agree on the transparency provisions at the end of the first week.
The Co-Chairs proposed asking the secretariat and CGE to prepare technical papers,
and hold intersessional workshops and expert dialogues. This was supported by some
Parties and groups, including the EU, Australia, US, AOSIS, and the EIG, but opposed
by the Arab Group, China, and Egypt. The US, EU, LDCs, AILAC, and AOSIS, among
others, proposed continuing work under the SBSTA during the second week, but this
was opposed by China for the LMDCs and the African Group, who said other pressing
items on the agenda also need sufficient negotiation time, in particular adaptation and
finance. Rule 16 of the UNFCCC draft rules of procedures was therefore applied, and the
transparency discussions will continue at the session in June 2020.
While it is not surprising that no real progress was achieved in the absence of a firm
deadline at COP25, the inability of Parties to agree is troubling. It shows that the
negotiations on transparency are political in nature despite having a specific and
highly technical mandate. Agreement on CRTs will not be possible without addressing
financial and capacity building support for developing countries to conform with
the new requirements; and striking a delicate balance between the harmonisation of

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reporting standards to allow comparisons between all countries on the one hand, and
the provision of flexibility on the other. In other words, the transparency negotiations are
quite tangled up with the larger political issues between Parties in the climate negotiations.
Adaptation communications registry

At COP25, Parties were expected to agree on whether the prototype registry for
adaptation communications, developed by the secretariat, will serve as the public
registry referred to in Article 7.12 of the Paris Agreement. However, the LMDCs and the
Arab Group argued that the adaptation registry must be discussed jointly with the NDC
registry. Although other developing countries urged agreement, or at least substantive
discussions, lack of agreement meant that it could not be finalised, and it will not be
available for Parties to use in 2020. Switzerland, for instance, noted in the Plenary
that it is unable to submit its adaptation communication because the launch of the
adaptation registry is held up.
Institutional arrangements for capacity building

Parties had also decided, in Katowice, to consider and adopt a decision on the
initial institutional arrangements for capacity building at CMA2; and to consider
recommendations made by COP25 on enhancing institutional arrangements for
capacity building. In Madrid, it was decided that the Paris Committee on Capacity
Building (PCCB), created in 2015, shall serve the Paris Agreement in accordance with its
The immense strength
mandate and terms of reference. It will report to both the COP and CMA.
of a unified front
amongst developing The priority areas for the PCCB and activities, adopted by COP in a related Decision
countries was once following the review of the PCCB, include: enhancing coherence and coordination of
again on display during capacity building; identifying capacity gaps and needs; and promoting awareness-
the 2019 review of the raising, knowledge- and information-sharing, and stakeholder engagement. The
activities are listed in an Annex to the COP Decision, which also agreed to extend the
WIM. While there is still
term of the PCCB for five years. The Committee is requested to extend its current rolling
much work to be done,
workplan to the end of 2020. The workplan for the extension period will be considered
and the governance at COP26.
of the WIM has yet to
be resolved, the review
has successfully placed WIM REVIEW, GOVERNANCE, AND FINANCE
addressing loss and
damage at the centre of Negotiations on “loss and damage” due to climate impacts are at a relatively nascent
taking action on climate stage under the UNFCCC, though the concept is at least as old as the Convention. AOSIS
change. had called for climate-related loss and damage caused by sea-level rise to be addressed
through an insurance pool in 1991, when the UNFCCC was being negotiated, but this
linda siegele aosis issue lay largely dormant over two decades, until 2013, when the WIM was finally set up
under the authority of the UNFCCC COP. Subsequently, it was agreed in Article 8.2 of
the Paris Agreement that the WIM will be subject to the authority of the CMA.
Governance arrangements
However, the inclusion of the WIM under the authority of the CMA in the Paris
Agreement resulted in a disagreement on the governance arrangements of the WIM, as
developed countries (particularly the US) then argued that the WIM should be under the
sole authority of the CMA, not of both the CMA and the COP (as developing countries
wanted).

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Other bodies, such as the Technology Mechanism and the Climate Technology Centre
and Network have similar joint governance arrangements, reporting to both the
COP and CMA. The position of the developed countries on limiting the governance
arrangements of the WIM to the CMA has been attributed to two reasons:
● Many developed countries would like to ensure that §51 of the Paris Decision,
which states that the Paris Agreement’s Article 8 (on loss and damage) “does not
involve or provide a basis for any liability or compensation”, applies to all discussions
on loss and damage.
● The US would like the loss and damage discussions to be limited to the Paris
Agreement, from which the country is withdrawing. This will effectively exclude
the US from any future discussions and obligations related to supporting
developing countries in dealing with climate-related loss and damage.
Developed countries were willing to compromise, but only if §51 of the Paris Decision
applies to the discussions under the COP as well. Despite efforts at the highest level
that continued into Sunday, 15 December, agreement proved impossible. Following
a compromise suggested by the COP Presidency, a procedural Decision was adopted
under COP, stating that discussions will continue at COP26 in November 2020 and
this does not prejudice the outcome of further considerations on the issue of WIM
governance. It is worth noting that although the WIM review was mandated by the COP,
the substantive Decision on the review was taken under the CMA, suggesting a clear
direction of travel (towards the CMA), despite the “without prejudice” wording.
“During the last two weeks we have had one Party who has been insisting that the WIM
operate under the Paris Agreement,” said Ian Fry, Climate Ambassador, Tuvalu, in his
statement to the closing plenary. “Ironically or strategically, this Party will not be a Party
to the Paris Agreement in 12 months’ time. This means if they get their way with the
governance of the WIM, they will wash their hands of any actions to assist countries
which have been affected by the impacts of climate change. This is an absolute tragedy
and a travesty on those affected by the impacts of climate change. There are millions
of people all around the world who are already suffering from the impacts of climate
change. Denying this fact could be interpreted by some as a crime against humanity.”
Funding for loss and damage

Developing countries had hoped that the occasion of the review of the WIM at COP25
would provide the opportunity to address finance for loss and damage in more concrete
terms, and to improve the institutional structure for loss and damage under the
UNFCCC to better deal with an increasingly pressing issue.
In a submission, the G77/China had called for:
● Developed countries to provide adequate, easily accessible, scaled up, new and
additional, predictable finance, technology, and capacity building for loss and
damage.
● The WIM Executive Committee to facilitate increased collaboration with bodies,
institutions and organisations under the UNFCCC on loss and damage finance.
● The operating entities of the UNFCCC Financial Mechanism to fund activities
related to loss and damage (some developing countries also wanted separate
funding windows for loss and damage under the operating entities).
● The SCF to collaborate with the WIM Executive Committee, and ensure that
guidance on funding for loss and damage is included in draft guidance to the

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operating entities of the Financial Mechanism.
● The GCF Board, to provide expedited access to adequate, scaled up, new and
additional funding for loss and damage.
In addition, the submission called for an expert group to be set up in 2020 under the
WIM Executive Committee, to enhance action and support; and for a “Santiago Network
on Addressing Loss and Damage” under the WIM, for the provision of technical support.
Some groups within the G77/China, such as the Bolivarian Alliance for the Peoples of
Our America (ALBA), also called for a separate financial mechanism under the WIM.
The Decision on the Others called for a separate “implementation arm” of the WIM, to complement the
WIM is bittersweet. existing “policy arm”.
Notwithstanding the
new channels for The SBs were unable to agree on these issues before the deadline of the end of the first
enhancing collaboration week of COP, and instead forwarded a draft conclusion with a bracketed draft decision.
between the WIM This still included different options on the mobilisation of finance, and on the expert
group and Santiago Network. Consultations continued under the guidance of the COP25
Executive Committee
Presidency during the second week, facilitated by ministers from Grenada and Norway.
and the SCF and GCF, In the end, a Decision was adopted under the CMA on 15 December. It:
and ostensibly catalysing ● Urges the scaling-up of action and support, as appropriate, including finance,
implementation under technology and capacity-building, in §32.
the Santiago Network, ● Urges private and non-governmental organisations, funds, and other
the finance elephant in stakeholders, to scale up action and support (§33).
the room is still roaming ● Acknowledges the wide variety of sources (public and private, bilateral and
multilateral, including alternative sources of finance) relevant to loss and damage
free. Until this issue
(§34).
is addressed with the ● Urges bodies, organisations and funds under and outside the Convention and the
sobriety and seriousness Paris Agreement to scale up support (§35).
that it deserves, the ● Invites Parties to make use of available support from a wide variety of sources,
climate emergency that “including through the operating entities of the Financial Mechanism, as appropriate,
Parties shout about from to an extent consistent with their mandates” (§36).
the mountain tops will ● Requests the WIM Executive Committee to engage with the SCF in accordance
with its mandate in Decision 2/CP.19 when the SCF provides draft guidance to
remain climate inertia
the operating entities of the financial mechanism (§37).
within the negotiating ● Requests the WIM Executive Committee to collaborate with the GCF to clarify
walls, to the likely how developing countries can access GCF funds to develop funding proposals
detriment of the most related to the strategic workstreams of the WIM’s five-year rolling workplan,
vulnerable societies. consistent with §36 (§39).
This is something we
will have to be prepared In a statement to the closing plenary, the G77/China noted with concern the absence
of a direct request to developed countries to scale-up action and support for loss and
to live with on both
damage in §32. While the previous version of the draft had urged developed countries
sides: realistically and
to scale up their financing to developing countries on loss and damage, the G77/China
conscientiously. representative said, it was revised to a generic reference to scaling up of finance in the
final version, without any reference to where it comes from. Others noted that the lack
kishan kumarsingh
of a reference to “new and additional” funding for loss and damage runs the risk that
trinidad and tobago
this funding will come from existing finance streams intended to fund mitigation and
adaptation. Finally, while Parties are invited to make use of “available support” from
the operating entities in §36, this is only to be done “to an extent consistent with their
mandates”.

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An expert group on loss and damage for action and support was established. It will
meet in 2020 to develop a focused plan of action that will, among other things, relate
to the activities on support for loss and damage in §§ 37-39 of the Decision, including
engaging with existing financial institutions within the UNFCCC to find ways of
enhancing the provision of climate finance for loss and damage. The expert group will
also collect, compile, and disseminate information on available sources of such support,
but its mandate does not include the mobilisation of new and additional finance.
It was also decided to establish, as part of WIM, the Santiago Network for averting,
minimising and addressing loss and damage associated with the adverse effects of
climate change, to catalyse technical assistance for the implementation of relevant
approaches at the local, national, and regional level. The Decision does not, however,
include a timeline for operationalising the Network.
Finally, the CMTA Decision calls on international entities, including financial

institutions, to continue supporting the development and implementation of measures
to avert, minimise, and address the adverse impacts of climate change. While loss
and damage is not specifically mentioned, developing country negotiators consider
it inclusive, especially since recent IPCC reports recognise that there are limits to
adaptation.
The next review of the WIM will take place in 2024, and every five years thereafter.
GENDER
The Lima Work Programme on Gender (LWP), adopted in 2016, and its Gender Action
Plan (GAP), adopted in 2017, were due to be reviewed at COP25. Negotiations on their
successors, the “enhanced” LWP and GAP, proved more contentious than usual, with two
issues at the centre of debate.
First, developing countries called on developed countries to provide the means of

implementation for the work programme and action plan, for developing countries and
the secretariat. Developed countries countered that financial issues should be discussed
and decided by those negotiating agenda items related to finance.
Second, references to human rights and a just transition were controversial. Some
developing countries were uncomfortable with blanket references to universal human
rights. They noted that the Paris Agreement lists specific human rights, not all. Parties
wrestled with ways to convey the multiple intersections of how place, race, and gender
increase vulnerability – for example, women from developing countries or indigenous
communities may face different types of vulnerabilities than women from developed
countries.
These issues were eventually resolved through consultations led by the COP Presidency.
On means of implementation, it was agreed to simply “invite” “Parties” to provide
support for developing country Parties, instead of “encouraging” specifically “developed
countries Parties”. On human rights, and on ensuring a just transition, the preambular
language already agreed in the Paris Agreement was simply reiterated.

www.ecbi.org 16
The enhanced Lima work programme (LWP) and its gender action plan (GAP) recognises
that climate change impacts on women and men can often differ owing to historical and
current gender inequalities and multidimensional factors and can be more pronounced
in developing countries and for local communities and indigenous peoples.
Parties are once again encouraged to appoint and provide support for a national gender
and climate change focal point (NGCCFP) for climate negotiations, implementation,
and monitoring. It invites them to submit information on efforts and steps taken to
implement the LWP and its GAP.
The UNFCCC secretariat is requested to continue to, among other things: prepare
an annual gender composition report and biennial synthesis report on progress in
integrating a gender perspective into constituted body processes; facilitate support for
building and strengthening the skills and capacities of NGCCFPs; and provide capacity-
building support to constituted bodies and the secretariat in integrating gender
perspectives.
The enhanced gender action plan retains the five priority areas of 2017-2019: capacity
building, knowledge management and communication; gender balance, participation
There is no clarity on
and women’s leadership; coherence; gender-responsive implementation and means
the financial support of implementation; and monitoring and reporting. Specific activities with assigned
that will be provided timelines, deliverables, and responsibilities are listed for each priority area.
for, and be accessible
by, developing countries The implementation of the enhanced LWP and GAP will be reviewed at SBI61 in 2024.
(not mobilised through Civil society groups have, however, already expressed concern over the lack of clearly
their co-financing). In defined indicators and targets for measuring progress. An intermediate review will take
place at SBI56, in 2022.
this situation, it is very
difficult for developing
countries to engage in
FINANCE
any process to enhance
ambition. If they do, they Four issues related to climate finance were discussed at COP25: long-term finance;
can only offer political several elements related to the Standing Committee on Finance (SCF); guidance to the
announcements and try Green Climate Fund (GCF) and Global Environment Facility (GEF); and the Adaptation
their best to implement Fund Board’s membership.
their unconditional
contributions to the Long-term finance
Paris Agreement. Long-term finance refers to the “US$ 100 billion annually by 2020” commitment, made
by developed countries in 2009. A work programme on long-term finance, first launched
kamal djemouai at COP17 in Durban, in 2011, was extended till 2020 at COP19 in Warsaw, in 2013. It
algeria included biennial submissions by developed countries on their approaches for scaling up
climate finance, in-session workshops, and biennial high-level ministerial dialogues. The
G77/China proposed a permanent forum to discuss long-term finance, saying the issue
needs regular discussion from a strategic perspective. Developed countries objected to
mandating the SCF to assess progress, saying it duplicated the SCF’s work on biennial
assessments, and also opposed extending the current work programme or creating a
new forum.
In the closing plenary, the African Group said the draft text proposed by the Presidency,
which “affirms the importance of climate finance and decides to continue discussion on this

www.ecbi.org 17
matter under the COP” did not reflect agreement reached in consultations the previous
night. They requested returning to the Group’s understanding of agreed language, which
specifies that discussions would continue at the next COP (“notes the importance to the
COP of continued discussions on long-term climate finance and decides to consider the matter
at COP 26”). Agreement was not possible as this wording was opposed by developed
countries, and it was decided that Rule 16 will apply.
Several developed countries linked long-term finance to results, pointing to the second
element on long-term finance in Paris Decision1/CP.21 (“…in the context of meaningful
mitigation action and transparency on implementation”), thereby linking long-term finance
with other contentious agenda items, notably NDCs and enhanced transparency.
Standing Committee on Finance

The SCF was established in 2010 with the express purpose of assisting the COP with,
among other things, “exercising its functions with respect to the financial mechanism of the
Convention in terms of improving coherence and coordination in the delivery of climate change
financing” and “rationalization of the financial mechanism”. Several Parties were therefore
disappointed by the absence of draft guidance from the SCF to the operating entities of
the Financial Mechanism at COP25. The SCF was unable to agree on this draft guidance,
and instead forwarded a compilation of submissions.
Common definition of finance

The SCF is also mandated to assist the COP with the “measurement, reporting and
verification of support provided to developing country Parties”. India, with other LMDCs,
and supported by other developing countries, pushed for retaining text calling on
the SCF to work on a “common” definition for climate finance that both developed
and developing countries agree on. Without a common definition, it is difficult to
determine (at least in a mutually satisfactory manner) whether financial commitments,
particularly the US$ 100 billion per year commitment, are being met. Developed
countries suggest there is a strong upward trend in the provision of climate finance,
while several developing countries remain sceptical. The call for a common definition
was opposed by developed countries, and the SCF workplan agreed for 2020 simply
underscores the SCF’s contribution to the operational definitions on climate finance. It
also invites submissions on this issue by 30 April 2020, to assist the SCF in preparing its
2020 Biennial Assessment and Overview of Climate Finance Flows.
Needs determination
At COP24 in Katowice, the SCF was requested to prepare, every four years, a report
on the determination of the needs of developing countries related to implementing
the Convention and the Paris Agreement, for consideration by the COP, starting
at COP26. At COP25, developing countries wanted to call on the SCF to make this
needs assessment “comprehensive”, so it can serve as one of the tools guiding the
replenishment of the operating entities. They also wanted to include loss and damage
in the needs assessment. Both suggestions were opposed by the developed countries.
The Decision encourages the SCF to present, “to the extent possible”, disaggregated
information on climate finance flows and the needs of developing countries, including
information on data availability and gaps by sector. On loss and damage, the Decision
notes the inputs the SCF has already provided to the technical paper on financial
support for addressing loss and damage; and “looks forward” to future input from the
WIM, on the SCF’s guidance to the operating entities of the Financial Mechanism.

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Synthesis report on the US$ 100 billion goal
The African Group wanted the SCF to prepare a synthesis report on the US$ 100 billion
goal, to inform the discussion on setting a new collective quantified goal from a floor of
US$ 100 billion per year, set to begin in November 2020. This was once again opposed
by developed countries. A proposal by AILAC to include an overview of the achievement
of the US$ 100 billion goal as part of the biennial assessment was also rejected by
developed countries.
Parties agreed to initiate the review of the functions of the SCF relating to the Paris
Agreement, aiming to complete the review in November 2022.
Guidance to the GEF and GCF

Work on these two items, regulars on the COP agenda, was more difficult this year
because the SCF did not provide draft guidance for the two operating entities of the
Financial Mechanism (see section on SCF).
In the discussions related to the GEF, developing countries raised the decline in climate
funding in the seventh replenishment; eligibility criteria for accessing GEF support; and
challenges with co-financing requirements. Among other issues, the guidance invites
the GEF to continue its efforts to minimise the time between the approval of project
concepts, the development and approval of the related projects, and the disbursement of
funds.
At the end of a year
when the devastating The operating entity is urged to continue to report any change or update to the eligibility
effects of climate criteria for accessing resources to the COP, including the System for Transparent
Allocation of Resources country allocation. There was a general push by many developing
change have become
countries to ensure that the guidance given by the COP on eligibility would not be re-
ubiquitous, the meager
interpreted or overridden by the GEF later on.
results of COP25 are
very disappointing. As The GEF is invited to consider ways to include LDCs and small island developing States
climate negotiator from in the fourth phase of the global project on technology needs assessments (TNAs), if
a small country, I am they have not undertaken a TNA. It is requested to “adequately support” developing
frustrated to see several countries in preparing their first and subsequent BTRs under the Paris Agreement.
big countries sabotaging
In its role in administering the LDC Fund, the GEF is requested to continue to provide
the multilateral climate
approved funding to countries transitioning from LDC status, for those projects
process and urgently approved before their graduation.
needed climate action.
The discussions on the GCF included: concerns about delays in accreditation, and calls
stefan schwager
for streamlining the process, particularly for Direct Access Entities; politicisation of
switzerland
project eligibility decisions; the need for information about actual disbursements; calls
for a strategic direction to address loss and damage and to establish an emergency
response window; the need to prioritise adaptation funding; and the insufficiency of
contributions during the Fund’s first formal replenishment.
The guidance to the GCF welcomes the pledges made by 28 contributors to the first
formal replenishment process, resulting in a nominal pledge of US$ 9.66 billion and a
"notional credit" of US$ 118.47 million that may be earned in the event all contributors
make early encashment. Further contributions are encouraged.

www.ecbi.org 19
The GCF is to “swiftly conclude” its work on the approach and scope for providing support
to adaptation activities, and to continue to enhance its support for the implementation
of National Adaptation Plans.
On loss and damage, the GCF Board is invited to “continue” providing resources for
activities aimed at averting, minimising, and addressing loss and damage, within
the existing investment, results framework, and funding windows and structures of
the Fund. “It is not clear what existing resources are available for loss and damage,”
commented a developing country negotiator in the aftermath of COP25. In this context,
the Board is asked to take into account the existing workstreams of the five-year rolling
workplan of the WIM. This falls short of the call for a dedicated GCF window for loss
and damage.
A further issue that came up at COP25 was that of “privileges and immunities” for the
GCF, as mandated in its Governing Instrument. Such privileges and immunities, secured
bilaterally with countries, allow the GCF to be more flexible in its project approval
process and legal agreements, and facilitates quicker access to GCF resources and faster
implementation of projects after Board approval. However, these arrangements are not
yet in place in most countries – as of May 2019, the GCF had bilateral agreements with
only with 21 countries. The issue will continue to be discussed at COP26. For now, the
GCF is encouraged to continue its efforts to procure bilateral agreements. Efforts by
the COP25 President to work with the UN Secretary-General, and explore a possible
institutional linkage between the UN and GCF to address this issue, are noted, with a
request for an update at the next Conference.
The Adaptation Fund Board and its Membership

At COP24 in Katowice, the CMA decided that the Kyoto Protocol’s Adaptation Fund
shall serve the Paris Agreement (exclusively, once the share of proceeds from the Paris
Agreement become available), and the CMP was invited to review the Adaptation Fund
Board’s rules of procedure in this context. Some developed countries have since called
for the membership of the Adaptation Fund Board to be revisited. Currently, a majority
of the 16 Board members (about 67%) are from developing countries.
A discussion on the composition of the Board took place in Madrid, under the CMA and
the CMP. Developing countries said the COP24 mandate does not include a revision of
the composition of the Board, and only refers to its rules of procedure. They wanted the
decision to be purely procedural. Other countries called for substantial changes. Japan,
for instance, called for the representation of developed countries to be enhanced, and
the Environmental Integrity Group wanted the Board’s composition to be revisited
depending on the source of funding.
The current language on the composition of the Board refers to two representatives
“from Annex I Parties”, and two from “non-Annex I Parties” (referring to Annex I of the
UNFCCC). Some developed countries supported draft text that replaced these references
to, respectively, “developed countries” and “developing countries” to reflect the grouping
of the Paris Agreement rather than the UNFCCC. This was opposed by developing
countries. No agreement was reached, and the discussion will continue at the June 2020
session.
In a CMP Decision that renews the World Bank’s role as interim trustee of the
Adaptation Fund, paragraphs related to Board membership were removed due to the

www.ecbi.org 20
ongoing disagreement. A decision was also taken for the GEF to continue to serve as the
Adaptation Fund’s secretariat. Unlike the past, when the interim roles of both the World
Bank and GEF were reviewed periodically, no timeline is established to review their role.
ADAPTATION
There are aspirations in the Paris Agreement and its rulebook that adaptation will receive
as much political and practical attention as mitigation. This is a long-standing concern
for developing countries, made more urgent by the IPCC’s 2018 and 2019 special reports
on Global Warming of 1.5°C, Oceans and Cryosphere in a Changing Climate, and on Climate
Change and Land, which issued a clarion call for urgent action, including on adaptation.
2019 also presented a first opportunity to add new issues to the CMA’s agenda – until
2018, CMA1 (first held in 2016) was “suspended” each year, until the completion of the
agenda items for CMA1. With the completion of the Paris Agreement rulebook in 2018,
new agenda items could be added for CMA2.
Adaptation remains of
urgent importance to The African Group proposed a new agenda item for the CMA on adaptation, to discuss
the reports of the Adaptation Committee (as already mandated), and a new sub-item on
small island developing
the global goal on adaptation. In an informal consultation, the African Group explained
States and it is worrying the importance of the global goal on adaptation and the lack of parity between this
how little progress was goal and the goals for mitigation and finance. Developed countries countered that
made on the issue at adaptation-related matters were agreed and mandated to various bodies, such as the
COP25.The divide among Adaptation Committee, so there is no need for further discussion.
countries on many issues
is also worrying given In the end, while there was no major outcome on adaptation, the CMTA Decision under
the CMA calls on countries to submit their first adaptation communication as soon
that everyone needs to
as possible and to engage in adaptation planning and implementation. It requests the
adapt to the impacts of Adaptation Committee to consider approaches to reviewing the overall progress made
climate change. in achieving the global goal on adaptation, and to reflect the outcome in its 2021 annual
report. It urges developed countries to provide financial resources to assist developing
sindy singh
countries with respect to both mitigation and adaptation, and earlier calls for a balance
aosis adaptation
between adaptation and mitigation funding are also reiterated.
coordinator
The CMTA Decision under the COP also includes several provisions on adaptation,
including recognition that the current need for adaptation is significant; greater levels of
mitigation can reduce the need for additional adaptation efforts; and greater adaptation
needs can involve greater adaptation costs. With regard to the IPCC reports, the SBSTA
is requested to hold dialogues on the ocean and climate change (on both adaptation and
mitigation related issues), and on the relationship between land and climate change
adaptation-related matters.
Report of the Adaptation Committee

Even the Report of the Adaptation Committee proved contentious at COP25, as
developing countries objected to the nature and extent of its focus on private sector
engagement. They felt the report and its recommendations neglected the full breadth of
the work of the Committee and obscured the role of developed countries in providing
public finance for adaptation. In the end, they were unwilling to even noting the report
“with appreciation”. No agreement was possible, and once again Rule 16 will apply
– discussions will continue in June 2020.

www.ecbi.org 21
Meanwhile, it is unclear how the Adaptation Committee will fulfil its role in serving
the Paris Agreement in 2020 without guidance from the CMA. Among the issues left
without guidance is the inventory of relevant methodologies for assessing adaptation
needs, which was mandated in Katowice. It is worth noting that the IPCC Working
Group II co-chairs declined the Adaptation Committee’s request for assistance, due to
the high workload associated with its sixth assessment report cycle. It is unclear how
this work will proceed.
National Adaptation Plans

The progress in formulating and implementing National Adaptation Plans (NAPs)
was considered at COP25, through informal consultations under the SBI. Many
developing countries described challenges in accessing funds for NAP formulation
and implementation, including from the GCF Readiness and Preparatory Support
Programme for the formulation of NAPs, with some citing a burdensome process. The
COP Decision on NAPs notes the challenges, and invites the delivery partners of the
GCF to strengthen efforts to support them with the goal of expediting the submission
of readiness proposals.
To find our way out of

READING THE RUNES
the Madrid cul-de-sac,
all three global goals 2020 is a crucial year for the fight against climate change. It is the year that
in the Paris Agreement implementation of the Paris Agreement is set to begin. It also marks the start of the
must be advanced with ten-year window of opportunity to keep global average temperature rise to 1.5°C, by
equal determination and reducing global emissions by 45% from 2100 levels by 2030. It can therefore either be
a turning point for climate change (if countries significantly raise the ambition of their
ambition.
NDCs), or the year that marked the beginning of the end for ecosystems that cannot
simon cardy withstand a warmer world.
south africa
2020 also marks the deadline for the US$ 100 billion annual commitment of developed
countries. The extent to which this commitment is delivered – and perhaps more
importantly, the extent to which developing countries agree that it has been delivered
– could have significant impacts on the already low trust quotient in the UNFCCC
process, alongside pre-2020 action. This latter element was already building momentum
at COP25. “There is a breakdown of trust, given that the political balance underpinning
Paris has been undermined, especially on pre-2020 issues as the basis of the transition
to Paris,” said one developing country negotiator. (In this context, developing countries
have it in their hands to make the Doha Amendment to the Kyoto Protocol enter into
force in 2020 and trigger scrutiny of developed country pre-2020 mitigation action –
only eight more countries need to ratify).
The perception that developed countries have not done their fair share pre-2020 combines
with the fear that they will not take responsibility in the post-2020 period either –
especially the country with the largest share of cumulative historical carbon dioxide
emissions. The US election in 2020 will indicate whether the US will definitely leave,
or potentially re-join the Paris Agreement. At COP25, the US continued to participate
in the development of the Paris Agreement rulebook despite its imminent departure,
exasperating many. “The refusal of developed countries to even acknowledge the US
problem (that the US had red-line positions that were incompatible with the multilateral
process on all issues under the Paris Agreement), let alone to shoulder some of the burden

www.ecbi.org 22
from the resulting gaps, took the oxygen out of the Conference,” a developing country
negotiator said. “We had the surreal situation where a Party exiting the Paris Agreement
was lecturing us on the ‘true’ meaning of the Paris consensus, around their interpretations,
backed by other developed countries. Developed countries in essence presented a united
front in allowing the US control over the Paris architecture even post-exit.”
The question of whether the UNFCCC process is “fit for purpose” has been asked before,
but never perhaps with the intensity that followed COP25. This can be attributed to
increased public scrutiny in the face of an imminent crisis, and the pressure is only
likely to grow in future. While many now feel that broader reforms are needed, this is
likely to be a slow process. In the short term, negotiators can increase their efficiency by
purging some of the bad habits they may have picked up along the way. “At COP25, we
were unnecessarily complicating negotiations even on procedural issues for the sake of
‘negotiation tactics’, resulting in a very dysfunctional process of decision-making,” said one
negotiator. “While this may have made sense while negotiating the Paris Agreement or the
Katowice rulebook, it should not continue – otherwise this process will become obsolete.”
The UK, as host of COP26, is described as a “safe pair of hands” recognised for its
diplomatic machinery, with a dedicated team of climate change diplomats based all
over the world (30 new climate experts have been hired for climate outreach). But
even this diplomatic behemoth may find it challenging to walk the tightrope that is
the Paris Agreement, while keeping all the balls in the air. Despite the importance of
mitigation pledges in 2020, the delicate “political balance underpinning Paris” must not
be forgotten. Mitigation ambition for some countries relies on the credibility of public
climate finance commitments, and the ability of the UNFCCC system to make the finance
available where it is needed, in a timely manner. At COP25, the sense that developed
countries were trying to downplay or wriggle out of their financial commitments (either
by objecting to direct references to developed countries in decisions related to the
provision of finance or, in the case of the US in the WIM discussions, completely trying
to wash their hands off responsibility) was far from helpful. Parity for adaptation action,
meanwhile, is becoming even more important, and the complete stonewalling on the
global goal on adaptation at COP25 was not confidence inspiring.
The UK will also have the chance to prove its diplomatic skills by delivering agreement
on Article 6. While some negotiators and observers seem to have given up on this issue,
lack of agreement could result in fragmented, increasingly volatile voluntary markets
and bilateral government-to-government programmes with limited international
oversight and transparency. This will limit the amount of finance mobilised by market
mechanisms, and smaller countries with limited capacities, in particular, will be
restricted in their opportunities for generating revenues for mitigation through market
mechanisms. Agreement on the Article 6 rules, on the other hand, could help increase
mitigation ambition in the short to medium term; harness private sector mitigation
action; deliver a system whose environmental integrity can be trusted; and create a level
playing field for all Parties.
COP26 will be under considerable pressure to deliver enhanced ambition on all elements
of the Paris Agreement, in the face of heightened public expectations and scrutiny.
Failure to deliver on these expectations will further undermine public faith in the
multilateral process.

www.ecbi.org 23
ABBREVIATIONS
ABU Argentina, Brazil, Uruguay
AILAC Independent Association of Latin America and the Caribbean
ALBA Bolivarian Alliance for the Peoples of Our America
AOSIS Alliance of Small Island States
BASIC Brazil, India, South Africa, China
BTR Biennial Transparency Report
CDM Clean Development Mechanism
CGE Consultative Group of Experts
CMA COP serving as Meeting of the Parties to the Paris Agreement
CMP COP serving as the meeting of the Parties to the Kyoto Protocol
CMTA Chile Madrid Time for Action
COP Conference of the Parties (to the UNFCCC)
CORSIA Carbon Offsetting and Reduction Scheme for International Aviation

CRTs Common reporting tables
CTFs Common tabular formats
GCF Green Climate Fund
GEF Global Environment Facility
IPCC Intergovernmental Panel on Climate Change
ITMO Internationally transferred mitigation outcome
LDC Least Developed Country
LMDCs Like-Minded Developing Countries
LWP and GAP Lima Work Programme and its Gender Action Plan
MPGs Modalities, procedures and guidelines
NIR National Inventory Report
NDCs Nationally Determined Contributions
NMAs Non-market approaches
OMGE Overall mitigation in global emissions
PCCB Paris Committee on Capacity-Building
PAWP Paris Agreement Work Programme
SBs Subsidiary Bodies (of the UNFCCC)
SBSTA Subsidiary Body for Scientific and Technological Advice
SCF Standing Committee on Finance
TER Technical expert review
TNA Technology Needs Assessments
UNFCCC United Nations Framework Convention on Climate Change
WIM Warsaw International Mechanism on Loss and Damage

www.ecbi.org 24
Edited by Anju Sharma ([email protected])
Funding Partner
ecbi Member Organisations
oxford
climate
policy
The contents of this report do not necessarily represent the views of the European Capacity Building Initiative (ecbi), any of its Members, or its funding partners.
European Capacity Building Initiative

ecbi Annex Offices
20 Linton Road
Oxford OX2 6UD
United Kingdom
www.ecbi.org Phone +44 (0) 1865 284 413
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COP25 KEY OUTCOMES

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COP25 KEY OUTCOMES

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● Re-emphasises the urgent need to address the emissions gap;

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● Bilateral or multilateral cooperative approaches, where Parties transfer

1. Draft text on Decision 1/CP.25, 13 December 2019 6 am

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The texts published on Saturday, in particular, had several compromises proposed on

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We are disappointed Article 6.4: Rules, modalities, and procedures

Options to account for transfers of mitigation outcomes expressed in non-GHG metrics

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ecbi European Capacity Building Initiative

While many expressed frustration at the lack of agreement on Article 6 at COP26,

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Common Time Frames

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Outlines of BTRs, NIRs, and TER report

Training programme for TER experts

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Adaptation communications registry

Institutional arrangements for capacity building

ecbi European Capacity Building Initiative

Funding for loss and damage

In a submission, the G77/China had called for:

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ecbi European Capacity Building Initiative

Finally, the CMTA Decision calls on international entities, including financial

First, developing countries called on developed countries to provide the means of

ecbi European Capacity Building Initiative

ecbi European Capacity Building Initiative

Standing Committee on Finance

Common definition of finance

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Guidance to the GEF and GCF

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The Adaptation Fund Board and its Membership

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Report of the Adaptation Committee

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National Adaptation Plans

To find our way out of

ecbi European Capacity Building Initiative

ecbi European Capacity Building Initiative

CORSIA Carbon Offsetting and Reduction Scheme for International Aviation

ecbi European Capacity Building Initiative

ecbi Member Organisations

European Capacity Building Initiative

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