Project developers urge governments to prioritise article 6 implementation as COP31 approaches

by Rob Hanley
7 minutes read

With the United Nations Climate Change Conference (COP31) set to take place in Antalya, Türkiye, from 9 to 20 November 2026, the Project Developer Forum (PD Forum) has called on governments and international climate institutions to accelerate the implementation of Article 6 of the Paris Agreement, outlining six priorities aimed at making international carbon markets more operational, predictable and accessible to credible climate projects.

The Forum’s recommendations come as cooperation under Article 6.2 expands, with more than 110 bilateral agreements involving 65 countries and a growing number of host countries establishing authorisation arrangements, including through Letters of Authorisation. While these developments indicate progress in creating the policy architecture for international carbon trading, the Forum argues that the next phase must focus on translating those arrangements into functioning systems capable of supporting investment and delivering measurable emissions reductions.

Article 6 provides a framework through which countries can cooperate in achieving their climate targets, including by transferring internationally transferred mitigation outcomes (ITMOs) between countries. Its implementation is expected to create opportunities for carbon finance to support emissions-reduction activities, particularly in developing economies where access to climate investment remains constrained. However, the effectiveness of the framework depends on the ability of governments to authorise transactions, account for transferred mitigation outcomes and ensure that emissions reductions are accurately reflected in national climate reporting.

The PD Forum’s first priority is therefore to move beyond continued rulemaking towards practical implementation of both Article 6.2 and Article 6.4. It argues that governments and international institutions should concentrate on establishing operational approval, authorisation and reporting processes, with clear institutional responsibilities and sufficient technical capacity. The Forum maintains that the time required to develop and finance climate projects makes delays increasingly consequential as countries approach their 2030 climate targets.

For project developers, the distinction between a framework being formally established and a market being operational is significant. A country may have an Article 6 policy or bilateral cooperation agreement in place, but developers still need to understand how projects will be assessed, how authorisations will be issued, what fees will apply and how corresponding adjustments will be recorded. Without functioning administrative processes, project development timelines can become uncertain, making it harder to secure buyers, financing and long-term investment commitments.

The second priority concerns policy certainty. The Forum is calling on host countries to establish clear and consultative Article 6 frameworks that reflect national circumstances while applying requirements consistently. These should include transparent procedures for project approval, authorisation of ITMOs, fees and corresponding adjustments, as well as clarity on the criteria used to grant authorisations and how decisions will be treated over time.

This issue has direct implications for the investment environment in developing countries. Carbon projects often require substantial upfront expenditure, long development periods and coordination among governments, communities, technical partners and buyers. Unclear fees, changing authorisation rules or uncertainty over the treatment of credits can increase project costs and weaken investor confidence. The Forum also argues that where governments collect carbon-related fees, revenues should be directed towards climate action and mitigation, supported by transparent reporting.

The third priority places national institutional capacity at the centre of Article 6 implementation. Developing countries need sustained technical and institutional support to strengthen greenhouse gas inventories, track progress against their nationally determined contributions (NDCs), maintain national registries and report ITMOs and corresponding adjustments accurately through biennial transparency reports.

The challenge is not limited to establishing registries or preparing reporting documents. Governments need experienced teams and reliable systems capable of tracking mitigation outcomes from project authorisation through to international transfer and national accounting. The Forum warns that some host countries are authorising projects faster than their inventory and reporting systems can accommodate. This creates a risk that the administrative process of issuing authorisations may advance without equivalent capacity to reflect transactions accurately in national climate reporting.

For African countries seeking to attract carbon-market investment, this capacity question is particularly important. Many are developing national carbon-market frameworks while also strengthening their emissions inventories, climate data systems and institutional coordination. Without adequate technical resources, countries may struggle to maintain accurate records, demonstrate the integrity of transferred credits or assess how international transactions affect progress towards their own NDC targets. External technical assistance can support this process, but sustained domestic expertise and institutional ownership will be necessary for long-term participation.

The fourth priority concerns interoperability between national and international systems. The Forum argues that national approval processes and registries must connect effectively with international infrastructure and market mechanisms, including the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). It is calling for progress towards systems that can record, track and report international transfers consistently, reducing duplication and uncertainty for governments, project developers and buyers.

The development of the United Nations Framework Convention on Climate Change (UNFCCC) registry is identified as an important part of this process. As carbon-market transactions increase, fragmented systems could make it difficult to establish the status of credits, verify transfers and maintain consistent reporting. Greater interoperability would help countries and market participants follow transactions across different systems while supporting the transparency required for international cooperation.

The fifth priority focuses on the Paris Agreement Crediting Mechanism (PACM), established under Article 6.4. The Forum is calling for methodologies based on robust scientific evidence and informed by the practical realities of implementing projects across different countries and sectors. It also wants host countries and project developers to have greater involvement in developing and revising methodologies, ensuring that technical requirements reflect national circumstances and project-level evidence.

The debate over methodologies is central to the credibility and accessibility of carbon markets. Methodologies determine how emissions reductions are calculated, monitored and verified. Requirements that are too weak could undermine environmental integrity, while rules that are excessively complex or poorly suited to project conditions could raise costs and prevent credible projects from participating. The Forum is therefore asking the Article 6.4 Supervisory Body to consider how individual requirements interact and what their combined effect means for project viability.

The sixth priority is to strengthen the investment case for high-integrity mitigation. The Forum argues that Article 6 should provide a credible route for private finance to reach projects in countries where other sources of climate funding are limited. Clear authorisation processes, reliable accounting and workable methodologies are all considered necessary to reduce uncertainty for investors and buyers.

It is also urging market participants to look beyond price when assessing ITMOs. According to the Forum, pricing should account for the integrity of the mitigation activity, its sustainable development benefits and the carbon-price context of the acquiring country. This reflects a broader concern that a market driven primarily by the lowest available credit price may not adequately reward projects that deliver stronger environmental and community outcomes.

The emphasis on sustainable development benefits is particularly relevant for developing countries, where carbon-market projects may support renewable energy access, cleaner cooking, forest conservation, waste management and other activities with economic and social implications beyond emissions reductions. However, the extent to which host communities benefit depends on project design, benefit-sharing arrangements and the way revenues are distributed and monitored.

The Forum’s final message concerns the role of project developers in shaping the rules governing the market. Developers work directly with host-country authorities, local partners, standards bodies and buyers, giving them practical experience of the administrative and financial challenges that can affect implementation. The organisation argues that this experience should inform government and international decision-making as Article 6 frameworks and methodologies continue to evolve.

As COP31 approaches, the six priorities place a practical implementation agenda before governments and international institutions. The expansion of bilateral agreements and authorisation arrangements represents progress, but the ability of countries to turn those commitments into functioning carbon-market systems remains the more consequential test.

For developing economies, particularly across Africa, the stakes extend beyond participation in international carbon trading. Article 6 could provide an additional channel for financing mitigation activities, supporting project development and attracting private investment. Yet this opportunity will depend on whether national institutions can provide predictable rules, credible accounting, transparent reporting and workable approval processes.

The central challenge for COP31 will therefore be to narrow the gap between the architecture of Article 6 and its delivery on the ground. Without stronger institutional capacity and greater policy certainty, the expansion of cooperation agreements may not translate into investment at the scale anticipated. With effective implementation, however, carbon markets could become a more practical source of finance for credible mitigation projects while supporting the climate and development priorities of host countries.

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