Making progress on climate finance
We need to address the governance problem
Summary
Since COP30 last November, climate finance has been stuck. The UNFCCC has agreed an ambitious long-term climate finance goal – for $1.3tn to flow to developing countries from all international sources by 2035 – but has not willed the means to achieve it. Recent years have seen a proliferation of initiatives aimed at scaling up climate finance flows from a variety of sources, and in 2025, under the auspices of the Brazilian COP presidency, two comprehensive reports were published on how the $1.3tn could be achieved. But at COP30 countries rejected the opportunity to advance these initiatives and reports under the UN regime, and a separate non-UNFCCC process involving finance ministries from 35 countries also failed to generate agreement on a way forward.
This short paper argues that further progress on climate finance will require the question of governance to be addressed. Currently there is consensus at COPs only on a narrow notion of governance which limits substantive decision making largely to the responsibilities of developed countries under Article 9.1 of the Paris Agreement. (The UNFCCC also has governance responsibility for carbon markets.) Under this narrow scope the $1.3tn will not be achieved. The principal losers will be those who need climate finance the most – low and lower middle income countries and SIDs.
The paper argues that, to achieve the $1.3tn, COP negotiators will need to accept a wider notion of governance on climate finance, consistent with Article 9.3 of the Paris Agreement. Under this, parties should accept that the UNFCCC cannot decide precisely how the $1.3tn should be raised; but it can and should ask other institutions and fora in the international financial system (such as the IMF, the Financial Stability Board and the G20), to consider and promote climate finance flows from a variety of sources. In turn, those institutions and fora should accept their responsibility to support the efforts of developing countries in addressing climate change by providing or encouraging finance for low carbon and climate-resilient development.
The paper suggests five specific initiatives which can be taken by the Turkish / Australian presidency of COP31 – ideally, as part of a troika with the Brazilian and Ethiopian presidencies of COP30 and COP32 – to advance this agenda:
• Establishment of the two-year climate finance work programme agreed at COP30 in such a way as to conclude with an agreed ‘global effort’ on all aspects of climate finance under Article 9.3, including an examination of reform of the international financial architecture as specified in the Mutirão decision.
• Establishment of the ministerial round table on NCQG implementation at COP31 in such a way as to kick off such a work programme.
• Securing agreement on the use of the Baku to Belém Roadmap as an input to these processes, through consultation with parties.
• An offer to Brazil to co-chair the Circle of Finance Ministers in 2026, with a focus on implementation of some of the recommended actions set out in the Circle’s report.
• Engagement with the UK government as it prepares for its G20 presidency in 2027
1: The state of play: from COP29 to COP30
In its decision on the ‘New Collective Quantified Goal’ (NCQG) for climate finance, COP29 in November 2024 agreed two numbers on how much money should flow to developing countries in the period to 2035. At least $300bn a year would be provided and mobilised by developed countries (formally, with them ‘in the lead’); and, as an aspirational goal, a total of $1.3tn annually should flow internationally from all sources by 2035. To bridge the gap between the two numbers, the decision tasked the COP29 and COP30 presidencies to produce a ‘Baku to Belém Roadmap to $1.3tn’ to show how the larger sum could be raised.
The wording of this decision left some unanswered questions about the $300bn: how much of this could come from non-developed countries, and how much could be ‘mobilised’ from non-public sources? But it left greater uncertainty about the remaining $1 trillion (of the $1.3tn), which by implication would need to be raised from other sources. Which sources? Who would be responsible for mobilising them, and how would this be done?
The proposal for a Baku to Belém Roadmap to $1.3tn was intended to offer answers to these questions. As the incoming COP Presidency, Brazil established two parallel processes. Working with Azerbaijan as mandated by COP29, Brazil’s COP30 presidency team (based in the Foreign Ministry) engaged throughout 2025 in a formal UNFCCC consultation process with parties and non-party stakeholders on what might be included in the Baku to Belém Roadmap to $1.3tn. The two presidencies published a Roadmap report on the eve of COP30 in early November.
At the same time, drawing on the experience of the ‘Task Force Clima’ which it had convened to bring G20 finance and climate ministries together in 2024, Brazil established a ‘Circle of Finance Ministers’ in early 2025 to consider the various financial sources and processes which would be required to achieve the $1.3tn goal. The Brazilian Finance Ministry, the Fazenda, invited its counterparts in 35 countries to join the Circle, convened meetings of their finance ministers at the IMF/World Bank Spring and Annual Meetings, engaged in consultations with a variety of public and private financial institutions, academics and think tanks, and published a comprehensive report in October 2025.
The Roadmap and Circle of Finance Ministers reports are structured differently, but cover the same ground, setting out all the different possible sources of finance which might make up the $1.3tn, and identifying short-term actions and decisions which would need to be taken by different financial institutions and fora to begin scaling up financial flows towards the goal.
Meanwhile, the Independent High Level Expert Group on Climate Finance (IHLEG), co-chaired by Amar Bhattacharya, Nick Stern and Vera Songwe, produced its fourth annual report, backing up the other two with even more detailed analysis of the uses of climate finance, its potential sources, and what will be needed to unlock them.
These three reports map out a comprehensive landscape of issues which need to be addressed, and early processes which need to be initiated, if climate finance is to be scaled up to $1.3tn annually by 2035. All start from a foundation of developed country public finance, mobilised in particular through a continued expansion of lending by multilateral development banks. But all acknowledge that there will also need to be major flows from other sources, including private sector finance, South-South contributions, resources raised through carbon markets, debt relief, new sources of earmarked taxation and others.
The analysis and proposals in these reports have been praised by many stakeholders in the non-UNFCCC-based climate finance community: financial institutions, think tanks and others. But neither of the official documents was well received within its own institutional forum. Finance ministries’ participation in the Circle of Finance Ministers processes and meetings was very variable: some engaged deeply, others much less. The two meetings intended to be for finance ministers themselves were attended by very few of them; most countries sent officials, some not particularly senior. The language in the final report recommendations was considerably weakened in the informal negotiation process. An accompanying communique was published alongside the Annual Meetings of the IMF and World Bank, but it stopped short of endorsing or even welcoming the report, and two of the 35 countries (Australia and Japan) did not sign it. (By contrast, the Chinese Vice Minister for Finance said that China ‘endorsed’ it.)
At COP30, the Baku to Belém Roadmap fared worse. Having been published only days before the opening of the conference and not being a formal item on the agenda, it was barely raised during the negotiations. Though there were obvious places where it was highly relevant – a key topic of the ‘Mutirão’ negotiations on non-agenda items was climate finance, and the final outcome includes a process to review implementation of the NCQG – the Roadmap was pushed only by Kenya (which had originally proposed it at COP29) and to a lesser extent by AOSIS. Brazil and Azerbaijan organised a side event to present the Roadmap during the middle weekend, but very few parties attended, and at the meeting the document was welcomed only by European countries and Canada. In the final Mutirão text the Roadmap was only ‘noted’, and no decision or process to take it forward was agreed.
COP30 has therefore left the field of climate finance in something of a limbo. While the goals for 2035 have been agreed, there is no accepted understanding within the UNFCCC of how the very significant gap from $300bn to $1.3tn can be bridged. COP30 did agree that adaptation finance should be tripled by 2035, but without specifying a baseline. Outside the UNFCCC, with the Circle of Finance Ministers report not fully accepted by most of the finance ministries which took part in its consultations, there is no guarantee that the Circle will continue.
This situation should be of concern to the majority of parties to the UNFCCC. For developing countries, particularly the LDCs and SIDs who need climate finance the most, it leaves little certainty about future flows. Only $300bn pa by 2035 can be predicted with any confidence; of this, the tripling of adaptation finance should amount to around $110-120bn, with the remainder for mitigation. (The NCQG figures are ambiguous on whether they include loss and damage, for which only very much smaller sums have so far been pledged.) This is nowhere near sufficient to meet developing country needs, and with the bulk going to mitigation there is a strong likelihood that LDCs and SIDS in particular will see only a small proportion of it.
But developed countries, too, should be concerned. So long as there is no agreement on the contribution which can be made (in particular) by private sector finance and by South-South transfers, there will inevitably be increasing pressure on developed countries to provide more in public finance. Having agreed, under huge pressure at COP29, that the $300bn was not necessarily a ceiling to their commitment, they will be nervous that COPs will keep coming back to this figure in an attempt to raise it. In a time of constrained overseas aid budgets, they will not welcome this.
Why was more progress not made in 2025 after the NCQG decision in 2024? Why was the Baku to Belém Roadmap not accepted at COP30, and the Circle of Finance Ministers’ report not accepted among the finance ministries consulted in its production? The answer is that there is no underlying agreement – indeed, there is major disagreement – on how climate finance should be governed.
2: Climate finance under the UNFCCC
It was clear in Belém that many developing country UNFCCC negotiators were uncomfortable with the whole concept of the Baku to Belém Roadmap. Inserted into the COP29 NCQG text by ministers during the final hours of negotiations in Baku, its production directly by the two presidencies – not through a negotiation – was not seen as a legitimate process. Although Brazil and Azerbaijan conducted consultations about it, the process was seen as essentially non-transparent, with no texts available before the final document was published, only days before the start of the COP. At the informal presentation event in Belém one developing country official noted that, as a non-negotiated document, it had ‘no status under the UNFCCC.’
The Circle of Finance Ministers process added to the disquiet. This did not have even the legitimacy afforded by the COP29 text. The 35 countries invited to join the Circle by Brazil were not representative of the UNFCCC membership; it was essentially a ‘G20 plus’ grouping of major economies and a few others apparently arbitrarily chosen by a single member state. Although the Circle report was semi-negotiated among the 35 countries, it was not agreed even by them.
Underlying the legitimacy problem is a deeper concern. Discussing as they do the relevant roles and responsibilities of the multilateral development banks, the International Monetary Fund, the private sector, financial regulators and other institutions, both the Roadmap and Circle reports go far beyond UNFCCC competencies in international law.
Although the Paris Agreement acknowledges that climate finance includes many sources, not just public budgets, and not just from developed countries, only one source is written as a legal obligation: Article 9.1 applying to public finance from developed (Annex 1) parties. All others are voluntary, or mentioned without requiring UNFCCC parties to take specific forms of action on them. In the NCQG, the $1.3tn is a responsibility of ‘all actors’, which has no meaning in international law, and there is again no specific requirement on any parties to oblige or encourage non-party actors to take any specific forms of action. UNFCCC negotiations on Article 2.1c of the Paris Agreement, which sets out the Agreement’s aim of ‘making finance flows consistent with a pathway towards low greenhouse gas emissions and climate-resilient development’, have demonstrated the same problem. With no responsibilities assigned to any particular parties, it is easy in the negotiations for some parties to resist decisions on forms of finance they do not support.
There is in fact fundamental disagreement on the sources of climate finance. Many developing countries continue to insist that the responsibility to provide climate finance rests almost entirely with developed countries under Article 9.1. Although developing countries are at liberty to provide climate finance if they so wish, they have no obligations and the UNFCCC can only at best ‘encourage’ them to do so (which the Paris Agreement does, in Article 9.2). Private sector finance, which developed countries see as essential and ultimately likely to provide the bulk of the $1.3tn, is regarded by many developing countries as, at best, legally irrelevant – it is not explicitly mentioned in the Paris Agreement – and at worse, simply a way for developed countries to escape their obligations under Article 9.1. At COP30 a significant group of developing countries insisted throughout that only the implementation of Article 9.1 needed further review under the NCQG.
So long as this view prevails at COPs, it is almost impossible for the UNFCCC to make any meaningful decisions on actions to be taken beyond Article 9.1. Accordingly, the $1.3tn will have no chance of being achieved.
The UNFCCC has governance over one other source of climate finance: the proceeds of carbon markets. Under Articles 6.2 and 6.4 of the Paris Agreement, the UNFCCC has established the rules under which both countries and companies can buy emissions reductions from developing countries. There are different estimates of the size of carbon markets which may result from its decisions, and some developing countries wish to exclude carbon market proceeds from the definition of climate finance altogether, but the primary governance responsibility is accepted.
Three chinks have appeared in the armour of resistance to widening the scope of climate finance beyond developed country public funds. First, COP decisions in recent years have acknowledged and encouraged wider sources of climate finance. From COP27 this has especially encouraged the expansion of multilateral development bank investment: as MDB shareholders include developing as well as developed countries, this has effectively widened the sources of climate finance encouraged by the UNFCCC. The COP30 Mutirão decision went much further: it ‘welcomes efforts to reform the international financial architecture, calls for continued efforts in this regard and notes the need to rapidly reduce existing constraints, challenges, systemic inequities and barriers in relation to access to climate finance.’
Second, the NCQG decision agreed at COP29 (Decision 1/CMA.6) explicitly widens the definition of responsibility for providing climate finance. Whereas at COP21 (Paris) the decision to establish a New Collective Quantified Goal referred only to developed countries, at COP29 (Baku) this became ‘with developed country Parties taking the lead,’ meaning that the $300 billion per year by 2035 agreed was not simply the responsibility of developed country parties. One specific source of non-developed country party finance for climate action was mentioned in the NCQG decision: paragraph 8(c) recognizes ‘the voluntary intention of Parties to count all climate-related outflows from and climate-related finance mobilized by multilateral development banks towards achievement of the goal set forth in this paragraph.’ Previously, in accounting for their climate finance flowing through MDBs, the developed countries had excluded such flows which could be attributed to developing countries’ capital shareholdings.
Third, a number of developing countries have now made significant commitments to climate finance. Though still legally voluntary, these have had the effect of blurring the division of responsibilities between developed and developing countries. The two largest contributors to the new Tropical Forest Forever Facility are Brazil and Indonesia. Mexico, Colombia, Peru, Panama, Vietnam and Indonesia have all made pledges to the Green Climate Fund. In 2024 China announced that it had ‘provided and mobilized’ the equivalent of US$24.4bn in climate finance since 2016, the first time it had formally given a figure for its South-South contributions.
These developments clearly provide both precedent and reason for the UNFCCC to consider, and make decisions on, sources of finance beyond public funds provided by developed countries. But for this to happen, the UNFCCC will have to accept a wider notion of climate finance governance.
3: Climate finance beyond the UNFCCC
The largest parts of both the Baku to Belém Roadmap and the Circle of Finance Ministers report are taken up with sources of finance that will be essential to achieve the $1.3tn goal but which are not governed by the UNFCCC. If more money is to flow from these sources, other financial institutions and fora will have to accept their responsibility to increase climate finance flows too.
This has already happened among the multilateral development banks. Over the last few years, the MDBs have accepted that the G20 has a role in their governance. With their consent, the G20 in 2024 adopted a ‘Roadmap’ committing the MDBs to expanding their lending through a number of instruments and reforms, with climate finance a particular focus for reform. Together, the major MDBs committed to increasing their climate lending to $120bn pa by 2030, and to mobilize a further $65bn pa from the private sector. The developed countries’ commitment at COP29 to $300bn of climate finance by 2035 was heavily dependent on the projected continuation of this expansion.
Just as the G20 has in recent years broadened its effective governance remit to cover the MDBs, so it has also taken a stronger governance role on sovereign debt. In 2020 it established the Common Framework for Debt Treatments, under which low income countries can engage with creditors to restructure their debts in times of debt distress. Although debt relief has not always been considered a source of climate finance, it is recognised as such in both the Baku to Belém Roadmap and the Circle of Finance Ministers reports. This is in response to increasing recognition in recent years that for some low and middle income countries with high levels of indebtedness, some form of debt relief may provide a source of, or even be a prerequisite for, new lending, whether for climate or other purposes. The 2025 report of the Expert Review on Debt, Nature and Climate advanced specific proposals to tie debt relief to climate investment, through ‘debt for climate’ swaps and more general mechanisms. While schemes of these kinds for individual countries do not need wider governance arrangements, any more general programme would almost certainly need G20 agreement, thereby placing another source of climate finance under effective G20 governance.
Beyond the MDBs and the G20, climate finance is not generally regarded as the responsibility of other financial institutions and their regulators. The International Monetary Fund does have a broad remit to consider climate change: it includes climate risks in its surveillance and analytical work, and its Resilience and Sustainability Trust advances lending to developing countries for resilience investments. But climate is very much a secondary concern to macroeconomic and financial stability.
Many central banks and financial regulators around the world are also concerned about climate risks, requiring the financial firms they regulate to report on this, and themselves conducting macro-financial risk assessments. But it is not within their governance responsibilities positively to promote climate finance flows, or to examine the regulatory barriers they may themselves have erected to such flows. Over the last few years a number of initiatives and reports have sought to identify such barriers and urge their removal, usually with the participation of the regulated sectors themselves. But it has so far been regarded as a governance step too far for the regulators. It is not within the remit of the primary international regulatory bodies, the Financial Stability Board, the Basel Committee on Banking Supervision and the Association of Insurance Supervisors.
Among the other potential sources of climate finance cited by the Baku to Belém Roadmap and the Circle of Finance Ministers report is taxation: either new international taxes from which part of the proceeds could be used for climate finance; or coordinated national taxes where participating countries commit to earmarking the revenues, or proportions of them, for international climate purposes. The Global Solidarity Levies Taskforce has examined the various possibilities. For potential international taxes, such as on shipping and aviation, governance arrangements do exist: the International Maritime Organisation has notably been considering the possibility of an emissions levy (though it now looks unlikely to be adopted). For coordinated national taxes there are no general governance arrangements: coalitions of willing countries would need to be formed, as has recently happened for air passenger duties on premium flyers.
This brief survey of the governance arrangements for different potential sources of climate finance indicates how difficult it will be to achieve the $1.3tn goal. Even if countries are sincere about their aspirational commitment to this goal in the UNFCCC, to achieve it will require actions and decisions in a wide range of other institutions and fora, most of which do not see climate finance as a primary responsibility or even any responsibility at all, and some of which are in any case at arms length from governments themselves.
Even within governments ostensibly committed to the $1.3tn global climate finance goal, the difficulty will be to get finance ministers to acknowledge that this will require action in areas beyond traditional climate or sustainable finance. Many exercise quite a strict separation between their various functions, so getting their divisions responsible for financial regulation or taxation even to consider climate concerns will not be easy. It will be made much more difficult by the general unwillingness of the United States under the current administration to consider climate issues at all.
There are two primary opportunities to overcome these challenges. The first is the Circle of Finance Ministers, which has done an important job of engaging finance ministries of the largest economies on climate finance issues. It needs to continue to do so. The second is the forthcoming UK presidency of the G20 in 2027. Notwithstanding its own recent ODA cuts, the UK government remains committed to supporting global development and climate goals, and its Treasury is better connected to the government’s overall climate finance commitments than its counterparts in many countries. It seems likely that the UK’s G20 presidency will wish to advance this field.
4: A new framework for climate finance governance
If progress is to be made on achieving the $1.3tn climate finance goal, it seems clear that a new approach will be needed to climate finance governance. This will need two core elements. The UNFCCC – the body with the broadest international legal legitimacy on climate change – will need to adopt a wider interpretation of its own governance remit. And a range of other international bodies, acting upon the instructions or guidance of the governments of (in practice) major economies, are going to have to accept a more important role in promoting climate finance.
4.1: Climate finance under the UNFCCC
It should not, in fact, be difficult for the UNFCCC to adopt a broader role in climate finance. Article 9.3 of the Paris Agreement is explicit about such a role. It requires that:
‘As part of a global effort, developed country Parties should continue to take the lead in mobilizing climate finance from a wide variety of sources, instruments and channels, noting the significant role of public funds, through a variety of actions, including supporting country-driven strategies, and taking into account the needs and priorities of developing country Parties.’
Since 2015 developed countries have tended to interpret this narrowly with reference to their own responsibilities. It is the prized clause which has enabled them to include a proportion of private sector finance within the sums they must report they have ‘provided and mobilized’, so long as the private capital has been leveraged (‘mobilized’) by public money. But Article 9.3 is not just about developed countries, and it does not limit the ‘wide variety of sources’ of climate finance to sums leveraged by public money. It insists on a global effort which developed countries must lead, but which is therefore evidently not confined to them. It refers to a wide variety of financial sources, instruments and channels, not just private sector finance. And while acknowledging the significant role of public funds in mobilizing other sources of finance, it insists that such mobilization can happen not just through this but through a variety of actions.
Under Article 9.3, it seems reasonable to say that the UNFCCC should be:
(a) seeking to promote a global effort on climate finance, including from developing as well as developed countries, and from non-sovereign finance providers as well as governments.
(b) defining this global effort to include all potential sources, instruments and channels of climate finance
(c) asking the developed countries to report what they have been and are doing to lead this global effort, including through the use of public funds but not limited to this
(d) asking other countries which are also contributing to the global effort (for example by providing South-South finance) to report on how they doing so
The reporting in (c) and (d) is required under Article 14.9: ‘Developed country Parties shall, and other Parties that provide support should, provide information on financial, technology transfer and capacity-building support provided to developing country Parties under Articles 9, 10 and 11.’ But it is notable that in their Biennial Transparency Reports published in 2025 countries have focused solely on the dollar sums they have ‘provided and mobilized’ under the narrow interpretation of Article 9.3; they have not reported on the efforts they have made to promote climate finance more widely as Article 9 requires.
If the UNFCCC is to take seriously its own aspirational goal of $1.3tn in climate finance flows by 2035, it will need to promote the global effort called for in Article 9.3. This effort should cover all the potential sources, instruments and channels of finance identified in the Baku to Belém Roadmap. The UNFCCC clearly cannot instruct non-UNFCCC bodies what to do. But it can certainly ask them to consider doing things. Indeed, it has already done that with respect to the MDBs. The COP27 cover text (Decision 1/CP27):
‘37. Calls on the shareholders of multilateral development banks and international financial institutions to reform multilateral development bank practices and priorities, align and scale up funding, ensure simplified access and mobilize climate finance from various sources and encourages multilateral development banks to define a new vision and commensurate operational model, channels and instruments that are fit for the purpose of adequately addressing the global climate emergency, including deploying a full suite of instruments, from grants to guarantees and non-debt instruments, taking into account debt burdens, and to address risk appetite, with a view to substantially increasing climate finance;
‘38. Calls on multilateral development banks to contribute to significantly increasing climate ambition using the breadth of their policy and financial instruments for greater results, including on private capital mobilization, and to ensure higher financial efficiency and maximize use of existing concessional and risk capital vehicles to drive innovation and accelerate impact.’
Such paragraphs offer a model for wider engagement on climate finance. Any international institution or forum can be similarly asked by the UNFCCC to undertake actions to promote climate finance as the UNFCCC sees fit. There is no obligation on any such non-UN institution or forum to do what it is asked by the UNFCCC; but coming from the globally legitimate UN body on climate change any such request would surely be taken seriously, particularly in institutions with governing bodies consisting of governments which had agreed to such text in the UNFCCC. The precedent, again, has been set by the MDBs: while facing no obligation to respond to the COP27 decision, the MDBs did, in fact, acknowledge the UNFCCC decision, and have collectively reported back each year since on what they are doing to fulfil the tasks asked of them by the UNFCCC. It is surely likely that other institutions asked by the UNFCCC to take actions, or consider taking actions, would do the same.
The role of the UNFCCC in climate finance being proposed here would therefore have four parts:
(1) Committing formally to a global effort on climate finance as defined by Article 9.3, involving all parties and all sources, instruments and channels of finance
(2) Making decisions on the elements of such an effort under its own governance control, primarily related to public and mobilized finance, UN climate funds and carbon markets
(3) Identifying actions to support this effort which other international institutions and fora would need to make; and asking those institutions and fora to take such actions, or consider taking them, and to report back to the UNFCCC on this
(4) Producing an annual or biennial report on the global effort
4.2: Climate finance beyond the UNFCCC
Whether in response to UNFCCC requests, or autonomously, a range of international institutions and fora are going to need to see an expansion of climate finance as part of their responsibilities if the $1.3tn is to be achieved. Clearly this will require decisions by their own governing bodies. In many cases – the G20, the IMF, the MDBs, the IMO – these governing bodies will be made up of governments also represented at the UNFCCC. There will need to be a degree of internal coordination within individual governments to ensure that decisions made in one forum are at least reflected in and consistent with those made in others.
This will of necessity make finance ministries critical actors. Most of the relevant non-UN bodies primarily have finance ministries as their key national interlocutors. This is why Brazil established the Circle of Finance Ministers: without finance ministry engagement, little progress can be made in many of the key fields. The experience of the Circle has in turn shown that many finance ministries are not yet sufficiently well informed or engaged to make decisions on climate finance which are within their governance responsibilities. (Within the Circle’s deliberations there was particular resistance to the idea of considering climate within financial regulation, and to a lesser extent in tax policy.) This helps makes the case for the Circle’s continuation: only with persistent engagement by finance ministries can many of the sources of climate finance be unlocked. It would be a great shame if the engagement achieved in 2025 was subsequently lost.
The membership of the Circle could however be improved. It is right that the world’s major economies are included: they are inevitably key decision makers at national level and within the G20. The other invitees should include ex officio the rotating chairs of the UN’s regional and other groupings (LDCs, SIDS, and so on), along with a cast of other countries to ensure balanced regional representation overall. These could be elected within the regional groups to ensure legitimacy. The Circle could be co-chaired by the current and future COP presidencies (in 2026, by Brazil and Turkey / Australia), with perhaps the current presidencies of the G20 and of the V20 as vice-chairs. The aim would be to give the Circle the greatest legitimacy possible in a non-UN body.
Having published a comprehensive report in 2025, the Circle of Finance Ministers should now focus on implementation. In 2026 and subsequent years, the Circle’s meetings should focus on a limited number of the recommended actions set out in the report and how they can be implemented. It could in turn report this to the UNFCCC at COP31 and subsequently.
5: Ways forward: the climate finance work programme and ministerial round table
How could this proposed new approach to the UNFCCC’s role in climate finance be advanced in 2026? Although COP30 did not agree explicitly to take forward the issues raised by the Baku to Belém Roadmap, it did decide on two mechanisms which could allow for them to be discussed.
First, Article 54 of the Mutirão text ‘decides to establish a two-year work programme on climate finance, including on Article 9, paragraph 1, of the Paris Agreement in the context of Article 9 of the Paris Agreement as a whole.’ Since ‘Article 9 as a whole’ explicitly includes 9.3, this is an opportunity for the full range of sources and recommended actions discussed in the Baku to Belém Roadmap to be considered.
It is strongly in the interests of all those parties wanting to see progress on the $1.3tn to shape this work programme in such a way that it leads to the explicit adoption of the wider notion of climate finance governance discussed here. It should conclude with a new ‘global effort’ as envisaged in Article 9.1, and effective agreement on the four-fold role of the UNFCCC as set out in section 4.1 above.
With further consultation among parties it may be possible to have the Baku to Belém Roadmap included as an input to this work programme, perhaps along with other relevant reports, including the fourth IHLEG report. As an input rather than an output, it may win greater acceptance. To add formal legitimacy there could be a role for the Standing Committee on Finance, for example to report to COP32 on progress made on the key sources of finance, and/or on the ‘global effort’ as a whole.
Given the support in the COP30 Mutirão decision for ‘reform [of] the international financial architecture’ and its call for ‘continued efforts in this regard’, noting ‘the need to rapidly reduce existing constraints, challenges, systemic inequities and barriers in relation to access to climate finance’, the work programme could include specific examination of these effort, constraints, challenges, inequities and barriers and how to overcome them.
Second, Article 52 of the Mutirão decision ‘decides to convene a high-level ministerial round table to reflect on the implementation of the new collective quantified goal on climate finance, including on the quantitative and qualitative elements related to the provision of finance.’ This Round Table, which should presumably be held at COP31, will need to consider all the sources of finance which could make up the NCQG goal of $1.3tn by 2035. It would therefore be an ideal way to kick off the two-year work programme. Again, the Baku to Belém Roadmap, IHLEG and other reports could be offered as inputs to the discussion. One of the advantages of the round table is the likelihood that ministers will want to discuss all the potential sources of finance which could be made available, less constrained by legal formalities than negotiators.
6: Conclusion and recommendations
Following COP30, moving climate finance forward will require that countries address the narrow conception of governance in the UNFCCC which now makes progress difficult. The key challenges are not now around Article 9.1: the developed countries have committed to a ten year target, and will not be pressured into raising it, at least until the NCQG review in 2030. Achievement of the $1.3tn goal will therefore require attention to be focused on the other potential sources of finance: the private sector, South-South finance, carbon markets, debt relief, new taxes and special instruments such as Special Drawing Rights and energy sector obligations. All these should be included in the ‘global effort’ envisaged in Article 9.3.
Defining such a global effort will require an acceptance that the UNFCCC should consider, and take decisions on, all potential sources, instruments and channels of climate finance. Such decisions should in many cases take the form of requests to other international institutions and fora to take decisions on, or otherwise consider, areas of climate finance which they govern. While such institutions and fora will retain, or need to adopt, the primary governance responsibility in their respective field, they should acknowledge the legitimacy of the UNFCCC asking them to consider how they can contribute to global climate objectives.
Five specific initiatives can be taken by the Turkish / Australian presidency of COP31 – ideally, as part of a troika with the Brazilian and Ethiopian presidencies of COP30 and COP32 – to advance this agenda:
• Establishment of the two-year climate finance work programme agreed at COP30 in such a way as to conclude with an agreed ‘global effort’ on all aspects of climate finance under Article 9.3, including an examination of reform of the international financial architecture as specified in the Mutirão decision.
• Establishment of the ministerial round table on NCQG implementation at COP31 in such a way as to kick off such a work programme.
• Securing agreement on the use of the Baku to Belém Roadmap as an input to these processes, through consultation with parties.
• An offer to Brazil to co-chair the Circle of Finance Ministers in 2026, with a focus on implementation of some of the recommended actions set out in the Circle’s report.
• Engagement with the UK government as it prepares for its G20 presidency in 2027
In order to pursue these aims, the Turkish / Australian presidency will need to engage in deep consultation with parties during 2026, including at informal gatherings such as the Petersberg Dialogue, and in Bonn during the intersessionals. In order to secure agreement it may be necessary to encourage a quid pro quo: developing countries agree to widen the climate finance agenda under Article 9.3, with the Baku to Belem Roadmap as an input, while developed countries make some commitments to a pathway for their climate finance contributions at least till 2030.
I would welcome comments on and reactions to this piece: please send them to m.jacobs@sheffield.ac.uk