Experts flag persistent gap between Article 6 intent and implementation
By Article 6 Network
.jpg)
Experts say most Paris Agreement parties are increasingly interested in Article 6, but a wide gap remains between countries expressing intent and those actually building the systems to operate in the market. The briefing reinforces a recurring message ahead of COP31: political will is no longer the bottleneck, and institutional capacity is.
According to the experts cited in the briefing, interest in Article 6 continues to rise across Paris Agreement parties. Yet relatively few countries have moved from statements of intent to the concrete steps needed to authorise, track and transfer mitigation outcomes.
The gap appears across several recent assessments. This year’s UNFCCC progress report on NDCs found that around 100 countries may use ITMOs to meet their 2025–2035 targets, up from the 89% of Parties that signalled possible Article 6 use in the 2025 synthesis. By contrast, the A6IP Center’s 2025 implementation status report counted 99 bilateral agreements or arrangements across 61 Parties. Only a small subset of countries have submitted Article 6.2 initial reports, issued Letters of Authorisation or recorded transfers.
Analysts have described the same pattern. After COP30, Rystad Energy concluded that the binding constraint is administrative capacity, with countries signing agreements before they can authorise, track and account for mitigation outcomes. Every Article 6.2 initial report reviewed so far has been flagged for inconsistencies. The UNFCCC has also warned that funding constraints are delaying key Article 6.2 infrastructure, including consistency checks and technical reviews.
Signals to watch
- Tiering of host countries: The market is splitting into a small group of operational hosts, such as Ghana, Thailand, Chile, Peru, Malawi and Rwanda, and a large group that has stated intent but is not yet ready. Supply, investment and buyer attention will concentrate in the first group until the rest catch up.
- Due diligence must test implementation, not intent: Investors and buyers should judge hosts on working systems: a submitted initial report, published authorisation procedures, an operational registry, LoAs issued and recorded first transfers. NDC statements and MoUs are weak signals on their own.
- Capacity building becomes a priority at COP31: Expect calls to scale up readiness support, including UNFCCC programmes, buyer-funded packages such as Norway’s, GGGI strategy guidance and climate-vulnerable countries’ handbooks. Decisions on stable infrastructure funding will matter as much as any new rules.
- Risk of lost time in the NDC period: Countries that take too long to operationalise may miss the window to generate and transfer ITMOs before 2030. Buyers with near-term NDC needs may then pay more for limited authorised supply from ready hosts.
- Private infrastructure fills gaps, with risks: Private registries and “Article 6 in a box” platforms are emerging to help lower-capacity hosts. They can speed up readiness but raise interoperability and sovereignty questions that governments must manage carefully.
Sources:
- IGES – Paris Agreement Article 6 Implementation Status Report: 2025 Edition
- Rystad Energy – COP30 review: few nations are Article 6 ready
- UNFCCC RCC MENA SA – Oman regional workshop citing 2025 NDC Synthesis Report
- UNFCCC – Technical paper on funding Article 6.2 infrastructure
