June 2026
Following the Bonn Climate Change Conference in June 2026, Article 6 has clearly moved from rule-making into implementation: raising a host of practical questions in its wake. The architecture agreed at the COPs in Glasgow, Sharm el-Sheikh, Dubai, Baku and Belém is now being tested against the day to day realities of establishing and running registries, authorising mitigation outcomes, funding market infrastructure, and understanding how both market and non market cooperation under Article 6 affects NDC implementation.
Exposure to these domains reveals a host of political, institutional and legal questions for the Article 6 rulebook, especially in areas where the negotiated outcome was left open for interpretation. Parties broadly converge on the need to operationalise Article 6 in a manner both inclusive and that preserves environmental integrity. However, it is clear they diverge sharply, on who should pay for the infrastructure, how far non-market approaches should evolve, how to manage overselling risks, and the cross pollination between the Paris Agreement Crediting Mechanism and Article 6.2 cooperative approaches.
While only Article 6.2 and Article 6.8 were on the formal negotiating agenda, the forum also played host to further discussions around both market and non-market approaches, and their broader ramifications related to the Paris Agreement Crediting Mechanism, the Clean Development Mechanism and CORSIA.
Article 6.2 provides the foundational procedures to generate and internationally trade mitigation outcomes, with important implications for NDC achievement.
The work to build out the UNFCCC infrastructure to support Article 6.2’s operations over the past few years has revealed clear concerns as to the sufficiency and stability of available funding resources. The cost of conducting Technical Expert Reviews and building and maintaining the International Registry and Additional Registry Services, in particular, is significant. Between 2024/2025 there was a shortfall of USD 7.3 million (Section III, Advance Technical Paper), hampering implementation, especially as it is a mix of both voluntary contributions and core UNFCCC budget.
While the negotiated outcome at Bonn, all Parties “took note of the significant gap in funding” identified in the technical paper and “expressed concern” regarding implementation of the Article 6.2 infrastructure and processes. They further took note of the updated technical paper on funding options in para 2 and the co-facilitators’ informal note in para 3. Paragraph 6 recalls para 30 of decision 19/CMA.7, urging voluntary contributions to the Trust Fund for Supplementary Activities to enable development, establishment and operation of Article 6.2 infrastructure, technical expert reviews and Secretariat capacity-building. Para 7 then urges the Secretariat to strengthen fundraising efforts, although the specific modalities of which were present in earlier drafts have been removed. Para 8 requests more detailed information, in the context of the annual Article 6.2 implementation report, on the assumptions underlying the supplementary budget, funds currently available, spending to date and expected remaining spending. Importantly, footnote 6–which was a red line for some Parties–clarifies that this request does not alter the agreed 2026–2027 budget or allocation across budget lines.
The co-facilitators’ informal note, designed to capture Parties’ views identified several competing principles vis a vis financing Article 6.2 including common but differentiated responsibilities and respective capabilities, user-pays, self-financing, equity, predictability and sufficiency. Some Parties saw core budget funding as appropriate for technical expert reviews and capacity building activities whereas others argued that Article 6.2 is voluntary and should not be financed through the general budget. Some favoured supplementary funding, others usage-based or user fees. All Parties were cognisant of parallel discussions in the budget room at Bonn, and not overstepping their mandate. The note explicitly records disagreement on whether fees would enable self-financing or discourage participation by Parties with limited capacity. The final outcome therefore avoids choosing among the contested funding models or prescriptively mandating the secretariat to organise pledging roundtables.
The political divide is thus clear. Developed-country Parties and some market-oriented Parties showed openness to user fees, usage-based fees and private actor contributions, particularly for registry services. Several developing-country groups, including AOSIS, LDCs, LMDCs, AILAC and AGN, emphasised that funding arrangements must not create barriers to participation or impose additional burdens on developing countries. This reflects a deeper disagreement over the normative character of the infrastructure for Article 6.2’s cooperative approaches: is it a global public good that supports the Paris transparency and accounting architecture, or a service used by participating Parties and authorised entities that should become at least partly self-financing? While the EU advanced the view that some elements were essential for environmental integrity and should be prioritised, such as the CARP, others stressed that Article 6.2 should be treated a complete package.
In the end, the SBI requested its Chair to prepare an informal document, including textual proposals, for SBI 65 with a view to recommending a draft CMA decision at COP31. This means the financing question remains open and is likely to be one of the central Article 6.2 issues heading into COP31 in Antalya.
Beyond the negotiations, the Article 6.2 Ambition Dialogue, held across the 11th and 13th of June also played an important role shaping discussions, in particular concerning how cooperative approaches interact with NDC implementation, ambition and long-term climate planning. Discussions on the first day focused on domestic institutional arrangements, with Parties including Zimbabwe, Bhutan, Japan and the EU outlining the governance structures, authorisation procedures and registry arrangements they have established to participate in Article 6.2. A recurring theme was the growing complexity of authorization decisions, with several Parties describing efforts to integrate Article 6 participation into broader climate governance frameworks, including NDC implementation, carbon budgeting and sustainable development planning. Zimbabwe, for instance, highlighted challenges associated with registry interoperability, reporting requirements and accounting for sustainable development benefits, while also noting concerns around alignment between Article 6 and CORSIA requirements. The EU used the Ambition Dialogue to situate Article 6 within its broader climate strategy, noting the Commission’s proposal to permit the limited use of high-quality international credits from 2036 onwards in support of its proposed 2040 climate target, while stressing that such cooperation must be aligned with Paris Agreement objectives and support transformative mitigation outcomes.
The second day shifted attention to cooperative approach design, focusing on baseline setting, additionality, permanence and environmental integrity. While Parties broadly agreed on the importance of ensuring that cooperative approaches remain aligned with NDCs and the long term goals of the Paris Agreement, different perspectives emerged regarding how this should be operationalised in practice. Several interventions highlighted increasing concern over the risks associated with overselling mitigation outcomes, particularly as countries begin to operationalise authorization decisions and assess how much mitigation can be transferred without compromising future NDC achievement. Observers and implementation partners emphasised the need for conservative baselines, robust accounting frameworks and stronger transparency around authorisation decisions. ENGO and YOUNGO participants argued that ambition discussions must move beyond transaction accounting and explicitly consider whether cooperative approaches are contributing to overall mitigation and sustainable development outcomes, TUNGO stressed that workers should not be left behind in the development of Article 6.2 and the IPO constituency also stressed that indigenous rights were currently lacking but essential in developing cooperative approaches. Across both days, a common thread was the recognition that Article 6.2 is no longer primarily a technical reporting exercise; it is instead becoming an increasingly contentious mechanism through which Parties must navigate how to preserve ambition whether as a host or buyer country whilst balancing national autonomy and ensuring environmental integrity, not just in theory but in practice.
Article 6.8 produced the clearest contrast between formal procedural agreement and substantive conceptual disagreement. The final negotiated conclusion under Article 6.8 initiated the review of the work programme under the Article 6.8 framework in para 1. Para 2 notes that SBSTA considered “without prejudice” to an outcome at COP31, the varying ways to implement additional NMA Platform functionalities enabling Parties to record projects identified under the Sharm el-Sheikh Mitigation Work Programme and enabling interconnection with other platforms. Para 5 requests the SBSTA Chair to prepare an informal document for SBSTA 65 which will be considered at COP31 (para 6).
This outcome represents a narrow procedural landing zone. It preserves space for further work without resolving the major conceptual disputes. The inclusion of “without prejudice” in para 2 was important: it allowed Parties to recognise that additional functionalities had been considered without implying agreement on their adoption or scope. Para 6 recalls para 10 of decision 4/CMA.3, anchoring the discussion in the original Article 6.8 work programme mandate, without recognising further openings. A request from AILAC to enable Party submissions to help inform the SBSTA’s Chairs note was rejected, with the LMDC noting they wanted to avoid an “arms race” of competing submissions.
The informal note shows why Parties could only agree on a procedural outcome. Parties converged on the view that Article 6.8 should support voluntary, Party-driven, facilitative cooperation and help connect national priorities with practical support. They also recognised the value of the NMA Platform, while noting that it has not yet reached its full potential, with calls for improving its usefulness through clearer submission templates, regional training, peer learning and simplified procedures. But divergence remains deep.
First, Parties disagreed over the scope of NMAs. Para 7 of the informal note records competing views: some Parties argued that the scope could be broadened by removing the requirement that an NMA involve more than one participating Party, while others argued that this requirement reflects the internationally cooperative nature of Article 6.8 and should not be altered. Para 9 of the outcome offers a possible bridge solution here whereby single-Party initiatives could be recorded as “potential” NMAs while they seek cooperation with another Party.
Parties also disagreed over the scope of additional platform functionalities, especially as they may come at a cost. Para 22 lists possible enhancements, including proposed NMAs, matchmaking, regional dashboards, project pipelines, capacity-building needs tracking, safeguards and co-benefit tagging, hyperlinks to other platforms, dedicated platform sections and even a data-aggregator function. Yet para 26 records that Parties also opposed adding further functionalities, citing low engagement and limited resources. Paras 28–30 show the associated tension: cost implications matter, but minor modifications might still assist Parties seeking finance, making it more implementable.
Third, Parties disagreed over the relationship with the Mitigation Work Programme. Paras 38–52 of the informal note record a wide range of views on whether and how MWP projects could be reflected on the NMA Platform. Some Parties saw this as a way to enhance visibility and implementation. Others stressed that the Platform must remain within the Article 6.8 framework and its agreed scope. Para 45 notes that MWP projects could already be recorded under the existing mitigation focus area if they meet NMA criteria, while paras 46–49 stress preservation of the Platform’s dedicated Article 6.8 function and careful consideration of resource implications.
Fourth, Parties remain divided on the future of the work programme itself. Para 35 records interest in discussing possible conclusion of the work programme as a negotiation item while maintaining the Platform and forum. Para 36 records the opposite view: that the work programme has not yet achieved its objective and that institutional-arrangement discussions are expected at CMA 9. This makes Article 6.8 a live governance question, not merely an exercise in platform design.
As Article 6.4 was not the subject of the same kind of negotiated outcome in Bonn as the other Article 6 provisions but it still remained a central part of negotiations. The Secretariat and implementation partners, such as GGGI, repeatedly presented PACM as operationalising, with registries, methodologies and transition processes moving forward. The Article 6 Markets Day materials framed the message as “Clarity. Readiness. Action”, and presented PACM as part of an Article 6 system that is no longer purely prospective.
The implementation signal is strong. As of June 2026, the UNEP-CCC noted 2,759 activities entering the PACM pipeline, including 1,515 CDM transition requests and 1,248 project concept notes, with 22 registered activities and two programmes having issued units. It also notes that the first two approved PACM methodologies already have a pipeline behind them, including around 90 activities and approximately 24 million tonnes CO2e per year of estimated mitigation outcomes.
However, Bonn also showed that PACM’s readiness narrative is inseparable from integrity scrutiny. Side-event discussions repeatedly returned to CDM transition risks, cookstove methodologies, over-crediting, permanence, conflicts of interest in validation and verification and concerns over the sustainable development implications of PACM activity. At the same time, Article 6.4 Supervisory Body members stressed that the PACM has already raised the bar relative to the CDM, that Sustainable Development Tool requirements apply to transitioned activities, and that methodology work remains ongoing. Some Parties, like the EU, shared their view that they are supportive of PACM being recognised as a Paris-aligned benchmark, but cognisant of the need for the mechanism to respond to criticism and avoid repeating Kyoto-era weaknesses.
Linked to the PACM via transition procedures, the CDM also featured in discussions. At a specific side event session on its wind down, it was made clear that it continues to shape Article 6 three key ways: as infrastructure legacy, as methodological inheritance and as cautionary tale. The Secretariat recognised that the CDM had developed more than 8,000 projects and a large body of methodologies, institutional practice and capacity-building experience. Since the decision at Belem for the cessation of its activities, it has been important to take stock of the steps for its closure as well as the implications on the PACM transitional pipeline.
In Bonn, the Secretariat also noted the 30th June 2026 deadline for approval of eligible activities and CERs into the Article 6.4 system. They also stressed that transition is not automatic, instead, requiring submission of addendum forms, information on the designated national authority, and Sustainable Development Tool, even though authorisation decisions can still come later. As a result, there is still little clarity on the size of the transition into the PACM, and how much of those transitioned units may then ultimately be used.
CORSIA was not negotiated under the UNFCCC in Bonn, but it strongly shaped Article 6 discussions given its requirement to adopt corresponding adjustments. The immediate relevance is that CORSIA demand depends on eligible units backed by host-country authorisation and corresponding adjustments. This places pressure on Article 6.2 systems, particularly Letters of Authorisation, reporting timelines, initial reports, Biennial Transparency Reports and registries.
The state of play emerging from Bonn is that CORSIA may become one of the most important near term demand sources for authorised mitigation outcomes, but supply remains constrained. Side event discussions at Bonn noted that CORSIA is both undersupplied and underpriced, with uncertainty around eligibility, authorisation and policy signals suppressing demand despite anticipated shortages. IATA and ICAO-related discussions highlighted host-country lack of awareness, the complexity of the authorisation, reporting delays and the need to align CORSIA unit generation with NDC ambitions.
CORSIA and Article 6.2 are now practically intertwined. Host countries, airlines, standards bodies and market intermediaries all need clarity on authorisation, corresponding adjustments and eligibility. However, just as airlines and market actors need eligible supply, host countries need to avoid overselling and preserve their ability to meet current and future NDCs. ICAO discussions can assess unit eligibility, but they cannot resolve complex questions about how much mitigation a country can safely export responsibly under Article 6.
For Article 6 governance, CORSIA therefore functions as both demand catalyst and stress test. It may accelerate operationalisation of Article 6.2 authorisation systems, but it also increases the importance of robust host country decision making, conservative accounting and clear benefit-sharing arrangements.
As we approach COP31 in Antalya the Article 6 system is operationalising unevenly. Article 6.2 has functioning reporting, review and registry needs, but its funding model is unresolved. Article 6.4 is moving toward implementation, but its legitimacy will depend on whether PACM can maintain a visibly higher integrity standard than the CDM and voluntary markets. Article 6.8 remains the least conceptually settled pillar, with Parties still divided over whether the NMA Platform should remain a narrow cooperation platform or evolve into a broader support and matchmaking architecture. The CDM is winding down, but its transition into PACM remains one of the most sensitive integrity questions. In the near term, CORSIA is creating demand for authorised units, but also intensifying host country concerns about overselling and undermining the achievability of an NDC.