Seeing clearly: transitioning to transparency at COP24

The Paris Agreement represented an important jump in ambition for transparent climate change reporting. Three years on, we are close to realising its 'enhanced transparency framework' (ETF) and there is reason for enthusiasm.

But as negotiators gather in Poland to agree the modalities, procedures and guidelines (MPGs) necessary to operationalise the new framework, some significant hurdles remain.

More inclusive, more complete

The ETF is a transparency upgrade. While the current Monitoring Review and Verification (MRV) system requires developed countries and ‘encourages’ developing nations to report climate action, the ETF requires all countries to do so every two years. This stronger ask is inclusive of poorer nations, notably least developed countries (LDCs) and Small Island Developing States (SIDS); but flexibility is built in for them so implementation of the ETF is in line with their capacities.

The ‘enhanced’ wording is earned by approaching climate action more holistically. The framework includes mitigation as well as adaptation and support; information requests are more frequent and more robust.

For example, countries must include the necessary information for tracking progress in implementing their Nationally Determined Contributions every two years, including relevant indicators and accounting approaches for mitigation targets.

Another new requirement asks developed countries to report fully on all types of support given to low-income nations for mitigation and adaptation action. In turn, developing countries are asked to report on support both received and needed.

The ETF is a step forward, as it should be. The framework is mandated by Article 13 of the Paris Agreement to ‘build on’ 20 years’ experience of UNFCCC transparency arrangements. It offers an opportunity to retain successful elements while making improvements based on lessons learned.

Facing a tough transition?

But before the new framework can be operational, its MPGs must be finalised at the 24th Conference of the Parties (COP24) in Katowice. While good progress was made during the last round of negotiations, one issue continues to spark uncertainty: how to manage the transition from the current regime.

Though barely mentioned in formal sessions – possibly to avoid stalling discussions – the potential hurdles have been a common talking point in corridors and informal meetings, signalling that this shift is less simple than it seemed.

Time at COP24 will be short, but guidance over the question of ‘transition’ to the ETF must crystallise before we all go home.

It’s time for certainty

One huge issue is timing. The Paris Agreement states that the ETF will ‘eventually supersede’ the existing regime. This is understood to mean it will come into effect immediately following the final biennial reporting under the MRV system. But no final submission date for these reports has ever been established; countries have no timescale to work to.

Leaving nations to self-determine when to transition to the ETF is not the best course of action for a fair and transparent start – a clear transition process and timeline should be agreed on together at COP24.

A level of urgency to start working with the ETF is felt nationally: the sooner countries report under the new system, the sooner they can assess the practical challenges they face and their capacity needs. It is also felt globally: a speedy start to ETF reporting will support both the success of the Paris Agreement and of the global stocktake.

With the first global stocktake slated for 2023, many countries – including LDCs – support the view that reporting under the new framework should start in 2022. But others argue for postponement to 2024 or even later.

A call for creativity and consensus

Dissenting views also exist over exactly what the ETF will supersede. Some countries argue that while current biennial reporting will be replaced, other national climate change reports stemming from obligations under the UNFCCC – such as national communications – will remain in place as they are.

But other negotiators argue this risks duplication. Guidelines for preparing national communications (which some countries view as vital and will keep submitting) are perceived to cover similar ground as the modalities, procedures and guidelines soon to be adopted under the ETF.

A future scenario in which multiple obligatory reports contain very similar content is a real problem, one that calls for creative solutions at COP24. Finding ways to capture and accommodate vital information across documents, while ensuring nothing is lost, will require flexible and consensus-building approaches.

How to implement the ETF – and specifically when – are commitments that ministers should be ready to consider as they join COP24. Trust and confidence in the Paris Agreement and its impact will depend on transparent reporting. We must make a smooth transition to the enhanced system as soon as possible.