Submission: Veredas Dialogue on the implementation of Article 2, paragraph 1(c), of the Paris Agreement and its complementarity with Article 9 of the Paris Agreement

February 2026

Introduction

We welcome the opportunity to comment on the organization of the reformed Art. 2.1c dialogues. We have been closely following and engaging with the previous Sharm-el-Sheikh Dialogues throughout their 3-year run, including participating in the workshops, hosting closed-door discussions with negotiators, and following the negotiations at COPs and in Bonn. In the process, CAN and individual members and allies have developed a body of publications and submissions around 2.1c, whose asks around content and format remain broadly relevant, such as:

On the organization of the Veredas Dialogue

The Sharm el-Sheikh dialogue (SESD) decision at COP30 recognized the continued differences in interpretation of Art. 2.1c’s scope or the manner of its implementation, and it seems that the Veredas Dialogue is now shifting towards focusing on implementation, including “challenges and opportunities”. We want to emphasize the importance of the Dialogue having a structured process to channel this exchange of implementation experiences into a framework that allows for a systematization of possible interpretations of the scope, implementation channels, and associated actors in the form of a “theory of change”, in the context of remaining enabling and non-punitive. It is also important that this framework has clear interlinkages with other UNFCCC processes. This should include how implementation of and reporting progress on Art. 2.1c can feed into the second Global Stocktake, the review of the Enhanced Transparency Framework and others, to strengthen UNFCCC processes so that they better facilitate and act as accountability mechanisms on Art 2.1c (as the decision sets out, the dialogues should contribute to other ongoing work and processes under the COP and the CMA, as appropriate).

The COP30 decision acknowledges the importance of pursuing all three long-term goals of the Paris Agreement (PA) together (para 3a), with Art. 2.1c key in facilitating the collective achievement of the goals articulated in Article 2.1(a–b). We also appreciate the consistent emphasis on a “whole of Art. 2” approach and complementarity with Art. 9 during deliberations both at COP30 and throughout the three years of Sharm el-Sheikh dialogue, which recognizes the historical responsibility of developed countries in creating the enabling environment and providing means for implementing Art. 2.1c to developing countries.

However, the Sharm el-Sheikh dialogue fell short of articulating a clear theory of change for Art. 2.1c – how specifically it would facilitate the achievement of Arts. 2.1(a-b), through which channels, policies and actors, what reforms of the financial architecture would be required beyond individual uncoordinated initiatives, and if and how those collective efforts would suffice to achieve Art. 2.1(a-b). Without this collective vision of its purpose, in line with the agreed safeguards, this new space risks becoming just a series of discussions on disparate and unrelated initiatives, with no clear pathway towards the collective achievement of the long-term goals of the Paris Agreement, contained in Article 2. Therefore, the Veredas Dialogue should frame the very important implementation discussion in a way that enables a vision and theory of change for Art. 2.1c to emerge from the practices shared, accompanied by clear proposals for the necessary reforms and transformations of the international financial architecture, and more direction on national actions with countries with the greatest capacity taking the lead in re-orienting their flows, being rooted in CBDR-RC and thus taking into account the bottom-up nature of the Paris Agreement and different national circumstances and time frames, while bringing countries together towards a common goal – achieving the whole of Art. 2. The second Global Stocktake process, beginning in 2026, offers a parallel vehicle to feed in elements of this vision, including acknowledgement of barriers and challenges, and eventually course correction pathways.

The resources linked above contain various concrete proposals for how the efforts and practices shared in the Dialogue could be systematized – for example, by how they contribute to different aspects of the PA’s goals, how they impact what type of finance flows, which actors/institutions are involved in realizing them, and what conditions or MOIs are required to realize them (such as the provision of financial support under Art. 9.1 as well as addressing the structural inequalities in the financial architecture tilting the playing field against developing countries and undermining their fiscal and policy space for taking climate action, including Art. 2.1c.). Another category for systematization can be what barriers need to be overcome. The final implementation of making financial flows consistent with low GHG emissions and climate-resilient development lies with a variety of actors, including financial and economic decision-makers and governance fora outside the UNFCCC, as well as different entities / actor groups within domestic policy ecosystems (the ODI paper shared above distinguishes between “internal” and “external” consistency makers, a framing mirrored in the Recourse paper that looks at the “external” international financial norm and standard setters specifically). Precisely because these actors shape capital allocation in practice, the Veredas Dialogue could be the space that helps us arrive at consensus on the directionality of alignment (shared principles, reference pathways, and minimum expectations), so that engagement beyond the Convention is anchored in an agreed UNFCCC theory of change. This substantive discussion could also benefit from a deeper engagement with the specific safeguards/guardrails acknowledged in the COP30 decision, to spell out what they imply for different policy pathways in substance.

To suggest a concrete format for the first Veredas Dialogue: it could be organized as Party-implementor discussion sets, wherein a Party/group of Parties bring forward a concrete alignment challenge (cost of capital barriers, underdeveloped domestic capital markets, Investor-State Dispute Settlement, greenwashing etc.) and discuss potential solutions as well as practical experiences with a selected set of ‘implementers’ or ‘internal and external consistency makers’ (regulators, FinMins, etc.). Civil society and academic experts remain an essential party to each combination. A future Dialogue could also put a spotlight on other parts of the UN system and discuss necessary connections e.g. with the Financing for Development space, where crucial systemic issues around debt, tax, trade, and global economic governance are negotiated that have considerable ramifications for the implementation of Art. 2.1c; especially considering that these connections are often lacking also within governments, with different Ministries negotiating in different UN fora or intergovernmental processes (e.g. the ongoing one on a UN Tax Convention), leading to a lack of a systemic perspective that understands climate and economic issues as interconnected and interdependent. Additional dialogues should put a spotlight on urgent issues that were not adequately addressed under the Sharm-el-Sheikh dialogues, such as the continued sovereign debt crisis and the financial system reforms required for a just transition away from fossil fuels.

On the format of the Xingu Finance Talks

The Xingu Finance Talks should follow the same principles of inclusivity, safeguards and objectives multilaterally agreed under the UNFCCC and the Paris Agreement as the Sharm el-Sheikh and Veredas Dialogues. We strongly caution against organizing them alongside events of other institutions or in countries that do not substantially uphold those same principles, in particular countries hostile to civil society and international financial institutions replicating unequal, neo-colonial power dynamics such as the IMF or the World Bank’s ICSID, an arbitration forum that facilitates a systemic barrier to climate finance and undermine countries’s policy space for necessary regulation. As described above, we are conscious that actors outside the UNFCCC make decisions and set conditions for the consistency of financial flows (or have proven to be an inadequate venue to address systemic barriers to financial flows) and indeed think that the Sharm el-Sheikh and now Veredas Dialogues should be a space to define and circumscribe their necessary roles. However, given their problematic track record (e.g. a governance structure that gives disproportionate power to historically large polluters with minimal to no voice for climate-vulnerable countries, and a history of structural adjustment programs that have deepened debt dependency, fossil extraction and environmental destruction), we think it is of the utmost importance that they be brought in only on the basis of a clear theory of change and with the agenda and directionality set by the UNFCCC – not the other way around.

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Submission: Veredas Dialogue on the implementation of Article 2, paragraph 1(c), of the Paris Agreement and its complementarity with Article 9 of the Paris Agreement

Introduction

On the organization of the Veredas Dialogue

On the format of the Xingu Finance Talks

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