6.1. Technical Details: Reporting Requirements

For a deeper exploration of the details included in the Paris Agreement Rulebook, the following content seeks to probe the decisions reached by the CMA on the reporting elements of the enhanced transparency framework. The framework was established to enhance the transparency of action and support with built-in flexibility taking into account parties’ different capacities and builds upon collective experience (article 13.1). To structure this exploration and provide some guidance for implementation, the discussion is focused on the key questions of who, what, when, and where; for more on this approach, please see the associated methodology.

WHAT? (FURTHER EXPLANATION OF “WHAT”)

Under the Paris Agreement, Parties report five different pieces of information:

  1. A national inventory report of anthropogenic emissions by sources and removals by sinks of greenhouse gases (shall be reported by each Party)
  2. Information necessary to track progress made in implementing and achieving NDCs under Article 4 (shall reported by each Party)
  3. Information related to climate change impacts and adaptation under Article 7 (should be reported by each Party as appropriate)
  4. Information on financial, technology transfer and capacity-building support provided and mobilized for developing country Parties (shall be reported by developed country Parties and should be reported by other Parties that provide support)
  5. Information on financial, technology transfer, and capacity-building support needed and received (should be reported by developing country Parties)

In addition, Parties will have to continue to meet their reporting obligations under the Convention; decision 1/CP.24 reaffirms reporting obligations under Articles 4 and 12 of the Convention (para. 40). All Parties will have to continue reporting national communications. Annex I Parties under the Convention will have to continue reporting annual national greenhouse gas inventories.

Different modalities, procedures, and guidelines apply for different reporting guidelines. The following figure illustrates the different modalities, procedures, and guidelines for Parties based on whether they are Annex I or non-Annex I Parties under the Convention and whether they are also Parties to the Paris Agreement.

Table showing Annex I Parties and Non-Annex I Party
1Note: 1/CP.24, para. 42 notes that for the purpose of fulfilling national inventory reporting obligations under the Convention, Parties to the Paris Agreement shall use the MPGs adopted in a decision 18/CMA. 1, Annex, Chapter II, "by the date that the reports are first due under the Paris Agreement."
2Note: 1/CP.24, para. 44 notes that Parties to the Convention that are not Party to the Paris Agreement may use decision 18/CMA.1 to fulfill their obligations under the Convention "to enhance comparability of information."

 In addition, the figure below shows the existing UNFCCC MRV system and the Paris Agreement’s enhanced transparency framework.

Figure showing existing UNFCCC MRV system and the Paris Agreement’s enhanced transparency framework.
Source: Dagnet, Y., N. Cogswell, N. Bird, M. Bouyé, and M. Rocha. 2019. “Building Capacity for the Paris Agreement’s Enhanced Transparency Framework: What Can We Learn from Countries’ Experiences and UNFCCC Processes?” Working paper. Washington, DC: Project for Advancing Climate Transparency (PACT)

WHO? (FURTHER EXPLANATION OF “WHO”)

All Parties shall report a national greenhouse gas inventory and information necessary to track progress in implementing and achieving their NDC. All Parties should report on climate change impacts and adaptation.

Developed country Parties shall, and other Parties providing support should, report on support provided and mobilized. Developing country Parties should report on support needed and received.

Small island developing states (SIDS) and least developed countries (LDCs) may report at their discretion (1/CP.21, para. 90). The Paris Agreement also provides flexibility in the implementation of the enhanced transparency framework “to those developing country Parties that need it in the light of their capacities. The modalities, procedures, and guidelines . . . shall reflect such flexibility” (Article 13.2).

WHEN? (FURTHER EXPLANATION OF “WHEN”)

The first biennial transparency reports (BTRs) are due at the latest by 31 December 2024 (18/CMA.1, para. 3). Parties, except for SIDS and LDCs, will submit their BTRs “no less frequently than on a biennial basis” (1/CP.21, para. 90). For Parties to the Convention and the Paris Agreement, Annex I Parties will submit their final biennial reports by 31 December 2022 and non-Annex I Parties will submit their final biennial update reports by 31 December 2024 (1/CP.24, para. 38). Biennial transparency reports will then supersede the requirements to submit biennial reports and biennial update reports (1/CP.24, para. 39).

The latest reporting year included in greenhouse gas inventories will be two years prior to the submission of the report. Developing country Parties that need it in light of their capacity have the flexibility instead to report data in their inventories three years prior to the submission of the report (18/CMA.1, Annex, para. 58). For example, a BTR submitted in 2024 would include data through 2022 (or 2021, for those developing country Parties applying flexibility).

The figure below illustrates the latest reporting year for greenhouse gas inventories in BTRs.

Figure showing latest reporting year for greenhouse gas inventories in BTRs.

WHERE? (FURTHER EXPLANATION OF “WHERE”)

Parties are to report through a “biennial transparency report” or BTR. Parties may also submit their national inventory report as a stand-alone document or as a component of the BTR (18/CMA.1, Annex, para. 12). If a Party submits its adaptation communication as part of its BTR, they should clearly identify which part of the BTR is the adaptation communication (18/CMA.1, Annex, para. 13). BTRs and NIRs if submitted as a stand-alone report will be submitted to the Secretariat via an online portal and may be submitted in any of the six official languages of the United Nations (18/CMA.1, Annex, paras. 15-16).

6.2. Technical Details: The Review Process

For a deeper exploration of the details included in the Paris Agreement Rulebook, the following content seeks to probe the decisions reached by the CMA on the review processes under the enhanced transparency framework. To structure this exploration and provide some guidance for implementation, the discussion is focused on the key questions of who, what, when, and where; for more on this approach, please see the associated methodology.

WHAT? FURTHER EXPLANATION OF “WHAT”)

The Paris Agreement established two different review and consideration processes: a technical expert review and a facilitative, multilateral consideration of progress (Article 13.11). These processes build off existing processes under the Convention—the International Assessment and Review (IAR) for Annex I Parties and the International Consultation and Analysis (ICA) for non-Annex I Parties.

The technical expert review will review consistency of the information submitted with the guidelines, consider the Party’s implementation and achievement of its NDC, consider support provided by the Party, identify areas of improvement related to implementation, and assist in identifying capacity-building needs for developing country parties that need it in the light of their capacities (18/CMA.1, Annex, para. 146).

The MPGs outline three different types of reviews for BTRs: desk reviews, centralized reviews, and in-country reviews. In a desk review, members of the review team will work remotely from their respective countries (18/CMA.1, Annex, para. 154). In a centralized review, all members of the review team will gather in one location (18/CMA.1, Annex, para. 152). In an in-country review, each member of the review team will travel to the Party under review (18/CMA.1, Annex, para. 153).

The following flow chart attempts to illustrate when BTRs will be subject to each of the different types of review.

Figure showing when BTRs will be subject to each of the different types of review.

 

In addition, annual greenhouse gas inventories from Annex I Parties may also be subject to a “simplified review.” Under a simplified review, the Secretariat undertakes “an initial assessment of completeness and consistency with the MPGs” (18/CMA.1, Annex, para. 155). Annex I annual greenhouse gas inventories are only subject to a simplified review in years in which BTRs are not due.

The following figure maps the applicable review format for Annex I annual greenhouse gas inventories.

Figure showing the applicable review format for Annex I annual greenhouse gas inventories.

When reviewing, the technical expert review team shall not:

  • Make political judgements (18/CMA.1, Annex, para. 149a)
  • Review the adequacy or appropriateness of an NDC (18/CMA.1, Annex, para. 149b)
  • Review the adequacy or appropriateness of indicators for tracking progress made in implementing and achieving the NDC (18/CMA.1, Annex, para.149b)
  • Review the adequacy of a Party’s domestic actions (18/CMA.1, Annex, para. 149c)
  • Review the adequacy of a Party’s support provided (18/CMA.1, Annex, para. 149d)
  • Review the Party’s determination to apply flexibility, including self-determined estimated time frames for improvements related to capacity constraints (18/CMA.1, Annex, para. 149e)
  • Review whether a Party has the capacity to implement provisions without flexibility (18/CMA.1, Annex, para. 149e)
  • Make information publicly available, if a Party has designated the information as confidential (18/CMA.1, Annex, para. 164).

The facilitative, multilateral consideration of progress will discuss the Party’s implementation and achievement of its NDC and efforts under Article 9 (18/CMA.1, Annex, para. 189). The following figure outlines the process for the FMCP.

Figure outlining process for the FMCP.

WHO? (FURTHER EXPLANATION OF “WHO”)

The Secretariat will form the technical expert review teams. To be eligible to serve on a technical expert review team, experts must be nominated to the UNFCCC roster of experts by a Party or, as appropriate, by an intergovernmental organization (18/CMA.1, Annex, para. 172). Experts must also complete the required training program, prior to serving on a technical expert review team (18/CMA.1, Annex, para. 173).

The expert review team:

  • Shall include experts with recognized competences in the areas under review (18/CMA.1, Annex, para. 175)
  • Shall include experts with collective skills and competences that correspond to the information under review (18/CMA.1, Annex, para. 176)
  • Shall include experts on each significant GHG inventory sector, mitigation and support, cooperative approaches and ITMOs, and LULUCF, as relevant (18/CMA.1, Annex, para. 176)
  • At least one team member fluent in the language of the Party under review, to the extent possible (18/CMA.1, Annex, para. 177).
  • Shall include, with a view to achieving balance, experts from developed and developing country Parties (18/CMA.1, Annex, para. 178)
  • Shall include geographical and gender balance, to the extent possible (18/CMA.1, Annex, para. 178)
  • Shall strive to include experts from LDCs and SIDS when LDCs and SIDS are undergoing a centralized group review (18/CMA.1, Annex, para. 178)
  • Cannot perform the review if the same team also performed the Party’s previous review (18/CMA.1, Annex, para. 179)
  • Shall include two lead reviewers—one from a developed country Party and another from a developing country Party (18/CMA.1, Annex, para. 181)
  • Shall fund experts from developing country parties participating in the technical expert review team according to the existing UNFCCC procedures (18/CMA.1, Annex, para.182)

WHEN? (FURTHER EXPLANATION OF “WHEN”)

The figure below illustrates the process for the technical expert review, which begins immediately after the Party submits its BTR (18/CMA.1, Annex, para. 162a). In short, the Secretariat will work with the Party to agree on dates for the technical expert review week and form a review team. The review team prepares for the review, communicates any preliminary questions to the Party, prepares a draft review report, and then prepares a final report based on Party comments.

Figure showing process for the technical expert review.

The timing for when a Party participates in the FMCP will be based on whether the Party has submitted a BTR and whether the technical expert review report has been published. The following flow chart maps these considerations.

Timeline for technical expert review process.

The full process for the FMCP is detailed in the figure below. Three months before the Party is scheduled to participate in the FMCP, an online portal will open allowing other Parties to submit written questions and the Party participating in the FMCP will make efforts to respond ahead of the working group session which will take place during a meeting of the Subsidiary Body for Implementation (SBI). During the session, the Party participating will make a presentation and then participate in a discussion session. Following the FMCP, the Secretariat will publish online a record of the FMCP.

Timeline for Facilitative, Multilaterial Consideration of Progress.

WHERE? (FURTHER EXPLANATION OF “WHERE”)

The technical expert review of BTRs will take place as a desk review, centralized review or in-country review. In a desk review, reviewers participate remotely from their desks in their respective countries. In a centralized review, reviewers gather in a single location (likely Bonn) to conduct the review. Reviewers for an in-country review will travel to the country for which the review is taking place.

The facilitative, multilateral consideration of progress will take place as soon as possible following the publication of a Party’s technical expert review report through an online portal and during meetings of the UNFCCC’s Subsidiary Bodies. The Subsidiary Bodies usually meet in Bonn in May/June each year and during the COP in November/December.

6.3. Technical Details: Flexibility in the Enhanced Transparency Framework

For a deeper exploration of the details included in the Paris Agreement Rulebook, the following seeks to probe the decisions reached by the CMA on flexibility under the enhanced transparency framework. To structure this exploration and provide some guidance for implementation, the discussion is focused on the key questions of who, what, when, and where; for more on this approach, please see the associated methodology.

WHAT? (FURTHER EXPLANATION OF “WHAT”)

The Paris Agreement provides flexibility “to those developing country Parties that need it in the light of their capacities” for implementation of the enhanced transparency framework. As Parties developed the modalities, procedures, and guidelines for the enhanced transparency framework, they agreed on the areas for which flexibility is provided.

The following table outlines the provisions where flexibility is explicitly provided. These MPGs specify the flexibility that is available to those developing country Parties that need it in the light of their capacities pursuant to Article 13, paragraph 2, reflecting flexibility, including in the scope, frequency and level of detail of reporting, and in the scope of the review, as referred to in decision 1/CP.21, paragraph 89.  All text in the table is copied exactly from decision 18/CMA.1.

Area for flexibility (decision 18/CMA.1, Annex) MPG provision (decision 18/CMA.1, Annex) Those developing country Parties that need flexibility in the light of their capacities with respect to this provision…
Key category analysis Para. 25 Each Party shall identify key categories for the starting year and the latest reporting year referred to in chapter II.E.3 below, including and excluding land use, land-use change and forestry (LULUCF) categories, using approach 1, for both level and trend assessment, by implementing a key category analysis consistent with the IPCC guidelines referred to in paragraph 20 above; […] have the flexibility to instead identify key categories using a threshold no lower than 85 per cent in place of the 95 per cent threshold defined in the IPCC guidelines referred to in paragraph 20 above, allowing a focus on improving fewer categories and prioritizing resources.
Uncertainty assessment Para. 29 Each Party shall quantitatively estimate and qualitatively discuss the uncertainty of the emission and removal estimates for all source and sink categories, including inventory totals, for at least the starting year and the latest reporting year of the inventory time series referred to in paragraphs 57 and 58 below. Each Party shall also estimate the trend uncertainty of emission and removal estimates for all source and sink categories, including totals, between the starting year and the latest reporting year of the inventory time series referred to in paragraphs 57 and 58 below, using at least approach 1, as provided in the IPCC guidelines referred to in paragraph 20 above; […] have the flexibility to instead provide, at a minimum, a qualitative discussion of uncertainty for key categories, using the IPCC guidelines referred to in paragraph 20 above, where quantitative input data are unavailable to quantitatively estimate uncertainties, and are encouraged to provide a quantitative estimate of uncertainty for all source and sink categories of the GHG inventory.
Completeness Para. 32 Each Party may use the notation key “NE” (not estimated) when the estimates would be insignificant in terms of level according to the following considerations: emissions from a category should only be considered insignificant if the likely level of emissions is below 0.05 per cent of the national total GHG emissions, excluding LULUCF, or 500 kilotonnes of carbon dioxide equivalent (kt CO2 eq), whichever is lower. The total national aggregate of estimated emissions for all gases from categories considered insignificant shall remain below 0.1 per cent of the national total GHG emissions, excluding LULUCF. Parties should use approximated activity data and default IPCC emission factors to derive a likely level of emissions for the respective category. […] have the flexibility to instead consider emissions insignificant if the likely level of emissions is below 0.1 per cent of the national total GHG emissions, excluding LULUCF, or 1,000 kt CO2 eq, whichever is lower. The total national aggregate of estimated emissions for all gases from categories considered insignificant, in this case, shall remain below 0.2 per cent of the national total GHG emissions, excluding LULUCF.
Quality assurance/quality control Para. 34 Each Party shall elaborate an inventory QA/QC plan in accordance with the IPCC guidelines referred to in paragraph 20 above, including information on the inventory agency responsible for implementing QA/QC; […] are instead encouraged to elaborate an inventory QA/QC plan in accordance with the IPCC guidelines referred to in paragraph 20 above, including information on the inventory agency responsible for implementing QA/QC.
Quality assurance/quality control Para. 35 Each Party shall implement and provide information on general inventory QC procedures in accordance with its QA/QC plan and the IPCC guidelines referred to in paragraph 20 above; […] are instead encouraged to implement and provide information on general inventory QC procedures in accordance with its QA/QC plan and the IPCC guidelines referred to in paragraph 20 above.
Gases Para. 48 Each Party shall report seven gases (CO2, methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6) and nitrogen trifluoride (NF3)); […] have the flexibility to instead report at least three gases (CO2, CH4 and N2O) as well as any of the additional four gases (HFCs, PFCs, SF6 and NF3) that are included in the Party’s NDC under Article 4 of the Paris Agreement, are covered by an activity under Article 6 of the Paris Agreement, or have been previously reported.
Time series Para. 57 Each Party shall report a consistent annual time series starting from 1990; […] have the flexibility to instead report data covering, at a minimum, the reference year/period for its NDC under Article 4 of the Paris Agreement and, in addition, a consistent annual time series from at least 2020 onwards.
Time series Para. 58 For each Party, the latest reporting year shall be no more than two years prior to the submission of its national inventory report; […] have the flexibility to instead have their latest reporting year as three years prior to the submission of their national inventory report.
Estimates of GHG emission reductions Para. 85 Each Party shall provide, to the extent possible, estimates of expected and achieved GHG emission reductions for its actions, policies and measures in the tabular format referred to in paragraph 82 above; […] are instead encouraged to report this information.
Projections Para. 92 Each Party shall report projections pursuant to paragraphs 93–101 below; […] are instead encouraged to report these projections
Projections Para. 95 Projections shall begin from the most recent year in the Party’s national inventory report and extend at least 15 years beyond the next year ending in zero or five; […] have the flexibility to instead extend their projections at least to the end point of their NDC under Article 4 of the Paris Agreement.
Projections Para. 102 [reference to paragraphs 93-101]     […] can instead report using a less detailed methodology or coverage.
Technical Expert Review Para. 159 [Reference to para. 158] A Party shall undergo an in-country review for: (a) The first biennial transparency report; (b) At least two biennial transparency reports in a 10-year period, of which one is the biennial transparency report that contains information on the Party’s achievement of its NDC under Article 4 of the Paris Agreement; (c) A biennial transparency report if recommended in the technical expert review of the Party’s previous biennial transparency report; (d) A biennial transparency report upon the request of the Party under technical expert review. […] have the flexibility to instead choose to undergo a centralized instead of an in-country review, but are encouraged to undergo an in-country review.
Technical Expert Review Para. 162c The technical expert review team should communicate any preliminary questions to the Party at least four weeks prior to the technical expert review week. The technical expert review team may request additional information before or during the technical expert review week. The Party concerned should make every reasonable effort to provide the requested information within two weeks of the request; […] are instead encouraged to provide the information within three weeks of the request.
Technical Expert Review Para. 162f The Party concerned shall then be given up to one month from its receipt to provide comments; […] have the flexibility to instead provide comments within three months of receipt of the draft technical expert review report.
Facilitative, multilateral review of progress Para. 192c The Party in question shall make best efforts to respond in writing to the questions no later than one month prior to the working group session through the online platform; […] have the flexibility to instead submit written responses up to two weeks prior to the working group session.

 

WHO? (FURTHER EXPLANATION OF “WHO”)

The application of flexibility is self-determined by Parties. Parties that determine their need to apply flexibility shall

  • Clearly indicate the provision to which flexibility is applied
  • Concisely clarify capacity constraints, noting that some constraints may be relevant to several provisions
  • Provide self-determined estimate time frames for improvements in relation to those capacity constraints (18/CMA.1, para. 6).

WHEN? (FURTHER EXPLANATION OF “WHEN”)

Parties will note where they have applied flexibility when submitting their BTRs.

6.4. Linkages with Other Elements of the Paris Agreement

Various elements of the Paris Agreement Rulebook are linked together, both implicitly and explicitly. These linkages build the Agreement’s plan-implement-review cycle and will support the implementation of the Agreement. This discussion details some of the linkages with the enhanced transparency framework, building on the efforts first elaborated in Dagnet et al. (2017) and Dagnet et al. (2018), and including updated information from the final decisions reached by the CMA.

Common Time Frames. These elements are linked, because the decision on common time frames will provide greater clarity on the end year/period of NDCs and thus define exactly when Parties would provide assessments of achievement of their NDC targets.  Under the enhanced transparency framework, Parties must “provide an assessment of whether it has achieved the target(s) for its NDC” in the “first biennial transparency report that contains information on the end year or end of the period of its NDC” (18/CMA.1, para. 70). A single common time frame will also align this reporting so that all Parties report on progress toward implementing and achieving their NDCs at the same point in the implementation of their NDC.

NDC Mitigation Elements. These elements are linked because Parties will report on progress made in implementing and achieving their NDCs, including its mitigation components, as part of the enhanced transparency framework. In addition, Parties must account for their NDCs in the biennial transparency reports under the enhanced transparency framework, including through a structured summary pursuant to the guidelines adopted in decision 18/CMA.1 (4/CMA.1, para 17). The accounting guidance in decision 4/CMA.1 is important for understanding Party reporting under the enhanced transparency framework. As part of the enhanced transparency framework, Parties are required to report on their accounting approach (18/CMA.1, Annex, para. 71, 74). Parties will also use indicators to track progress made in implementing and achieving their NDCs. These indicators will be “relevant to a Party’s NDC” (18/CMA.1, Annex, para. 65) and are a critical link between NDCs and the enhanced transparency framework. The review processes under the enhanced transparency framework (the technical expert review and the facilitative, multilateral consideration of progress) will consider implementation and achievement of the NDC, including its mitigation elements (Paris Agreement, Article 13, paras. 11-12).

Adaptation Communications. These elements are linked because Parties may submit their adaptation communication “as a component of or in conjunction with other communications or documents. . .” (Paris Agreement, Article 7.11). This means Parties could submit their adaptation communication as part of their biennial transparency reports. Further, decision 9/CMA.1 solidified a linkage between adaptation communications and the enhanced transparency framework in deciding that “Parties may, as appropriate, also submit and update their adaptation communication as a component of or in conjunction with the reports on impacts and adaptation as stipulated in Article 13, paragraph 8” (9/CMA.1, para. 4). However, if a Party submits its adaptation communication as part of the biennial transparency report, “it should clearly identify which part of the report is the adaptation communication” (18/CMA.1, para 13).

Ex-ante Finance Information. Linkages between the ex-ante communication of finance information under Article 9.5 and the enhanced transparency framework are indirect. Under Article 13, Parties report only on ex-post finance provided, mobilized, needed, and received. Some argue that it would be ideal to conduct comparisons of ex-ante and ex-post finance information. These comparisons, though, are not mandated or requested under either Article 9 or Article 13.

Cooperative Implementation (Article 6). While negotiations around Article 6 are still ongoing, linkages with the enhanced transparency framework have been established. Paragraph 77d of decision 18/CMA.1 outlines a number of additional reporting requirements for those Parties participating in cooperative approaches (though the details of the structured summary are still under negotiation and the information described in paragraph 77d is without prejudice to the outcomes of negotiations under Article 6). Further linkages are likely to be defined as Parties finalize negotiations on Article 6, including linkages between the governance and expert review of Article 6.2 and the Article 13 technical expert review.

Global Stocktake. The Paris Rulebook established several linkages between the enhanced transparency framework and the global stocktake, with the transparency framework informing the work and assessments of the global stocktake. The global stocktake is to consider the state of greenhouse gas emissions, the progress made in implementing NDCs, the state of adaptation efforts, and finance flows based on information provided under Article 13 (19/CMA.1, para. 36). Party reports under the enhanced transparency framework are an important source of input to the global stocktake (19/CMA.1, para. 37).

Facilitating Implementation and Promoting Compliance. There are direct linkages between the enhanced transparency framework and the Article 15 expert committee. The committee will initiate consideration of issues if a Party fails to submit a biennial transparency report and the information required under Articles 13.7 and 13.9 or does not participate in the facilitative, multilateral consideration of progress under the enhanced transparency framework (20/CMA.1, para. 22). Further, based on the technical expert review reports prepared under the enhanced transparency framework, the committee, with consent of the Party, may consider issues “in cases of significant and persistent inconsistencies of the information submitted…with the modalities, procedures, and guidelines” of the enhanced transparency framework (20/CMA.1, para. 23).

 

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