With implementation rather than negotiation as its focus, COP30 features 2 weeks of discussion about mitigating global climate change without the party that has historically influenced those discussions most – the United States. This analysis breaks down how much that really matters, what issues host country Brazil plans to emphasize, and what the event means for carbon markets – particularly trading of mitigation outcomes under the Paris Agreement’s Article 6.

Introduction

The 30th Conference of the Parties (COP30) under the United Nations Framework Convention on Climate Change (UNFCCC, the parent treaty to the Paris Agreement) starts next week in Belem, Brazil. Given that the Paris Agreement is now a decade old, and that COPs since its adoption by the UNFCCC’s over 192 parties (countries) have focused on hammering out its rules and procedures, Belem is being characterized as the “implementation COP:” parties are convening to see how they are finally putting those rules and procedures into practice. Planned negotiations are no longer about haggling over the terms of the Paris Agreement, but about whether and how parties are actually doing all the things those terms require of them.

State of play

On the one hand, that implementation is indeed moving forward- parties are largely following through on the Paris Agreement’s requirement that they set climate change mitigation targets (Nationally Determined Contributions or NDCs) every five years. However, this is happening too late given that the self-set submission deadline for 2035 NDCs was Q1 of this year and parties had already extended it informally to September, with many parties, including eg South Korea , not having formally submitted an NDC days before the conference begins, and EU member states coming to an agreement on the Union’s contribution only this week.

Those NDCs are supposed to be consecutively more ambitious (i.e. self-set emissions limits should be getting tighter with each NDC), but the degree to which that is the case is rather subjective, given countries’ evolving economies and the role of fossil fuel combustion in them. Analysis of the NDCs submitted so far shows they are woefully inadequate for keeping global average temperature rise under 2 degrees Celsius.

Procedurally, however, governments are keeping up with the Paris Agreement’s reporting requirements, which can be no small feat for poorer countries lacking the capacity for such documentation. Parties have been submitting their inventories, biennial transparency reports, and biennial update reports on progress toward their NDCs – again with many behind schedule, but at least following the process they collectively adopted.

No United States

Implementation is moving forward without one of the most influential parties to the Paris Agreement: the US is not sending an official delegation from its state department (=foreign ministry) to the climate negotiations. This is not because President Trump withdrew the US from Paris: by the agreement’s own terms, a party’s withdrawal only becomes effective an entire year after the withdrawing party has notified the secretariat. Since the Trump administration submitted a withdrawal notification in early 2025, the US is currently still theoretically bound to its obligations under the Paris Agreement – including participating in COP30, continued reporting obligations, and its national climate change mitigation target for 2030-2035 (see Textbox 1) – through January 2026

However, back in November 2024 we pointed out that the extent to which Trump would ignore these obligations remained to be seen – his administration has broad authority to weaken or cancel US climate targets and to simply not send a delegation to the COP.

Indeed, that is exactly what has happened, with executive decrees and acts of Congress gutting substantial parts of the Inflation Reduction Act, whose measures would have contributed toward the US achievement of its NDC, and US Secretary of State (=foreign minister) Marco Rubio eliminating the office that oversees international climate change negotiations for the US in April 2025. That office worked alongside the (now also eliminated) Office of the Special Presidential Envoy for Climate, a position created under the Obama administration held by former US Senator and presidential candidate John Kerry, and most recently under the Biden administration by John Profeta.

How much does US absence matter?

If Belem is about implementation rather than negotiation, the absence of the party that is typically the most bullying negotiator may be less impactful than it might have been at other COPs. No other country has submitted a Paris Agreement withdrawal notice to the UNFCCC secretariat. Also, American efforts to mitigate climate change are not bound to the national level: the US Climate Alliance, a coalition of governors and other legislators from 24 states including some of its largest economies like New York and California, wrote a letter to the UNFCCC after Trump sent the US withdrawal reaffirming its commitment to achieving the US Paris Agreement goals on a subnational basis. The members of the alliance have a cumulative GDP larger than that of China, accounting for nearly two-thirds of the total US economy. Members of this group met at a pre-COP event in Rio de Janeiro earlier this week, where they circulated a report stating their states have collectively decreased their annual greenhouse gas emissions by 24 percent from 2005 to 2023 while increasing their collective GDP by 34 percent in that same timeframe.

Furthermore, several members of Congress from Trump’s own republican party intend to attend COP30. Senator John Curtis from Utah and Senator Chris Coon, a democrat from Delaware, will co-lead a delegation to Brazil according to media reports that also mention at least three other members of Congress going. The main reason is promoting nuclear power as a carbon free energy source.

While the most obvious blow to global climate change mitigation from the US not participating in the Paris Agreement is that it is no longer “even trying” to decrease its emissions in line with its Paris Commitment target, the emissions trajectory of the US economy is not directly controlled by the executive branch – rather, it is a result of aggregate activities including fossil fuel combustion, greenhouse gas emission intensity improvements, etc. that are influenced by the ruling administration’s policies but ultimately subject to market forces. The abundance of cheap natural gas that rendered coal-fired power production unprofitable in the us decades ago – added to faster market penetration of renewables all over the world – has caused US overall GHG emissions to decline more than any policies the respective executive branches have passed over that timeframe. Thus, the influence of the Trump administration and a Republican Congress is limited when it comes to US emission reductions.

Biggest loser: climate finance

However, the part of global climate change mitigation Trump and Congress have more direct control over is finance. COP negotiations last year in Baku, Azerbaijan, were dominated by this issue, codifying a “new collective quantified goal on climate finance” under which rich countries agreed to raise at least $300 billion per year by 2035 in order to fund climate adaptation and mitigation efforts in poorer nations.

The amount was already far lower than what negotiators from poor countries had pushed for, and the actual contributions toward it have fallen well short. Brazil’s COP30 president Corrêa do Lago has pointed out that the US withdrawal from the Paris Agreement raises concerns among other rich countries about filling the financial gap left by the US. After COP29, the governments of Azerbaijan and Brazil created a ‘Baku to Belém Roadmap’ to be discussed at a high-level event at COP30, but none of the documents under its purview contain any implementation language and the roadmap does not appear prominently on the COP30 agenda. It is not subject to negotiation by governments, and the measures it identifies are not formally part of the Paris Agreement.

With a legislature unwilling to commit taxpayer dollars to mitigating global climate change, the US under the Biden Administration had been trying to incorporate the private sector into carbon finance – that was the goal of its now defunct “energy transition accelerator” promoted at (but not taken up by) previous COPs. Biden’s climate team had also tried to incorporate voluntary carbon market standards, registries, and crediting into US federal climate change mitigation activities (as well as characterizing US companies’ corporate involvement in international offset projects as part of the US contribution to Paris Agreement mandated climate finance) in an effort to at least be seen to be working toward achieving the Paris Agreement’s finance goals. Consequences of this include the disproportionately large participation of private sector entities at COPs, as well as efforts to incorporate corporate goals and standards into elements of the Paris Agreement such as its Article 6.

Implications for carbon markets

Indeed, Article 6 is a prime example of COP30 being about implementation: for the first time in nearly a decade, there will be no formal negotiations about this part of the Paris Agreement – the part that governs parties’ “cooperative approaches” to meeting their climate change mitigation targets. While previous COPs featured fights over the rules of how mitigation achieved in one party could be bought and used toward the mitigation target of another, those rules have largely been hammered out (see detailed outcomes of last year’s Article 6 negotiations in our “who got what” AU from 2024 and developments on Article 6.4 since then) and the focus has shifted to implementing them.

That implementation of Article 6 is indeed moving forward: preliminary agreements and memoranda of understanding to cooperate on emission reduction projects abound. An Article 6 implementation status report found parties implementing the UN guidance on how to transact mitigation outcomes amongst each other under Article 6.2, with many having arrangements in place for authorization and tracking of Internationally transferable mitigation outcomes (ITMOs). Parties now have a template for transactions of ITMOs under Article 6.2 that standardizes such transactions by offering boxes to check so that countries do not have to formulate explanations of their actions with each separate documentation. Countries have been submitting documentation of their activities under Article 6.2 for the mandated Technical Expert Review (TER), and there is synthesis report on the few TERs of 6.2 activities that have already started. The reviews, however (here are those of Thailand and Ghana), have no enforcement function: they can only highlight inconsistencies, not stop activities from going forward. In theory, parties can still proceed with questionable ITMO transactions.

Also, crucial elements necessary for transacting mitigation units (as opposed to merely agreeing to transact them) are still missing. Applying a corresponding adjustment, for instance, is a mandatory element of any Article 6 transaction – it is the accounting measure ensuring that when a unit of climate change mitigation is achieved, only the entity that paid for it can apply it toward its target. Given that the “target timeframe” for which transferred ITMOs are being “used” (added for the buyer, deducted for the seller country) is 2030, applying a corresponding adjustment currently only constitutes noting/acknowledging it to the extent possible in biennial transparency reports and biennial update reports. So far only four “seller” parties (Ghana, Guyana, Thailand, and Zimbabwe) have submitted any details on Article 6 implementation as part of their biennial transparency reports – many seller countries simply have not furnished those reports to the UNFCCC yet, given there are five years left in the 2025-2030 NDC period to which the corresponding adjustments apply.

This means that on the buyers’ side, a letter of authorization (LoA) from the seller country is “all there is to go on” in terms of accountability that these essential procedures for avoiding double claiming of mitigation outcomes have been implemented. Private sector entities have contributed to progress on this front, with many voluntary standards coming up with template LoAs similar to the UNFCCC’s ITMO template, so seller countries do not have to formulate explanations on a case-by-case basis. Whether and how governments will use the fact that they are all together in one place to facilitate progress in these implementation matters remains to be seen – the COP schedule does contain sessions pertaining to an “Article 6.2 ambition dialogue” on November 10 and 12.

Given that transactions under Article 6.4 of the Paris Agreement are governed by UNFCCC institutions rather than bilaterally by parties, “progress” on implementation of 6.4 can be expected to be more evident at COP30. The Supervisory Body of the Paris Agreement Crediting Mechanism (PACM) is meeting in Belem, and stakeholders will be watching. So far, this body has favored doing things right over doing things fast (see our analysis of the Article 6.4 Supervisory Body’s guidance on permanence), which has made progress on implementation of Article 6.4 slow compared to the ad-hoc deals being made by countries under 6.2. Only last week did the Supervisory Body approve the first methodology under the PACM. With the deadline for CDM projects aiming to continue to use CDM methodologies under the PACM ending in December, this will be a major point of discussion at the COP.

The aforementioned agreement on a formal NDC by the EU yesterday is also relevant to Article 6, as the bloc’s 2040 emission reduction goal the Paris Target aligns with explicitly specifies the use of international credits. EU as a whole will be able to use such credits to satisfy up to 5 percent of the collective 2040 target starting in 2036 and possibly as early as 2031, depending on what constitutes a “pilot phase.” EU member states are granted an additional option to further use credits to meet their national goals towards 2040, see our detailed take on the agreement here. This signals there will be demand from Europe for ITMOs, which in turn incentivizes proper implementation of the procedures necessary for ITMO transactions, including authorization, registries, and proper application of corresponding adjustments.

Brazil’s plans: staying vague

Although the Brazilian COP presidency has put forward many announcements and intentions – including a vast array of interconnected topics on an “action agenda,” each supposedly tied to a dedicated working group and discussion forum – the overall structure of the conference and goals of the host presidency remain vague.

Brazilian Environment Minister Marina Silva is keen to continue global efforts to end the use of fossil fuels – at the UNFCCC intersessional meeting in June 2025, she referenced the above-mentioned Baku-Belem roadmap on finance and indicated she would like to come out of COP30 with a mandated group providing a similar roadmap for the transition away from fossil fuels. Text in the outcome document from the 2023 COP in Dubai explicitly mentions transitioning away from fossil fuels and phasing out fossil fuel subsidies, but at COP29 Saudi Arabia successfully blocked any mention of fossil fuels in final decision texts. The schedule for COP30, however, contains no dedicated session for this roadmap or for negotiations specific to fossil fuel phaseout texts.

Given the COP’s location in the rainforest, Brazil is also looking to focus on rainforest protection – its new fund, the ‘Tropical Forest Forever Facility,’ will be formally launched at COP30 in cooperation with several other countries.

Of most relevance for carbon trading is Brazil’s plan to introduce an Open Coalition for Carbon Market Integration. The COP presidency has made announcements about this endeavor that indicate it would try to get major emitters on board with taking on some type of emissions caps, and with creating a carbon border adjustment mechanism that differs from that of the EU in that it would “not create a financial flow from poorer nations to wealthier ones.” The plan does not specify which “carbon credit trading systems” would be included. The initiative, led by Brazil’s Ministry of Finance, would consist initially of a “voluntary group of countries” that would join their carbon pricing measures. Given that Article 6.4 of the Paris Agreement already creates a crediting mechanism that all parties (and even private sector players) have access to, it remains to be seen what this idea means for parties and how it can even be negotiated within the UNFCCC process.

Will implementation bring accountability?

With little to negotiate over given the focus on implementation, the teams of diplomats each party sends to the annual climate talks may spend time on elements of the Paris Agreement that have flown under the radar screen but are essential to its function. One such element is transparency and enforcement, the rules for which took years to negotiate and are now being operationalized but have largely been overlooked by the media and stakeholders.

There has been plenty of attention on the fact that many parties have not submitted their NDCs yet, as well as that the ambition of NDCs is not high enough to mitigate climate change enough to keep global temperature rise under 2 degrees Celsius, but the Paris Agreement also requires parties to show they are trying to achieve their NDCs – that is why they submit the aforementioned biennial transparency and update reports. The entities that evaluate – essentially judge – parties on those, however, are…other parties. The closest thing the Paris Agreement has for “enforcement” is a process called the facilitative, multilateral consideration of progress or FMCP. As per the Paris Agreement, all 192 parties to it must get their biennial transparency report (BTR, the explanation of progress toward their NDC) “peer reviewed” by other parties, meaning it is subject to questioning.

The first stage of the FMCP is a written process – parties ask questions in writing and the party being considered must answer them. The second stage is a dialogue during UNFCCC meetings. Parties are up for review based on the order in which they submitted BTRs. The UNFCCC Secretariat estimates that between 20 and 30 Parties would need to complete the FMCP during each session of the SBs and COPs in order to complete the two-year cycle in a timely fashion.

The very first such peer review occurred in June 2025 at the 62nd meeting of the UNFCCC’s subsidiary bodies in Bonn (SB62). Andorra, Guyana, and Panama were the parties receiving feedback, as they were among the first to submit their BTRs. According to the Secretariat, they received many written questions – but from only a small group of “evaluator” parties: Australia, Canada, EU, Japan, Netherlands, New Zealand, Republic of Korea, and the UK. It remains unclear how the process will work when high-emitting countries are up for review, like China, India, Brazil, Russia, Indonesia, or the EU. The countries undergoing FMCP at COP30 are the European Union, South Africa, Cote d’Ivoire, Finland, Kazakhstan, the Netherlands, Slovakia, Spain, and Switzerland. The technical expert review of China’s BTR was conducted in June, so it will be subject to FMCP at COP31 in 2026.

Logistics

Meetings associated with the UNFCCC and its bodies are already on the official COP schedule: the FMCP, for instance, is an event of the Subsidiary Bodies for Implementation (SBI) and scheduled to take place on 15 November.

In contrast to previous COPs, heads of state will meet not at the very end of the second week of the summit to horse trade over the final points their diplomatic teams have managed to whittle the negotiating texts down to. Instead, a Heads of State Summit is happening prior to the actual event on 6-7 November. In line with its vague approach to crucial topics, the Brazilian presidency maintains this format allows “for better reflection,” perhaps emphasizing that adopted texts are not the main result of a COP focused on implementation.

Nevertheless, the schedule does label most days of the COP’s second week as “high level segments” (which are typically attended by government officials closer to head-of-state level), and each day from 11-20 November includes at least one timeslot designated for “negotiations” – there is therefore clearly an expectation that the event will result in some sort of officially adopted text.