On 10 September, speaking in Trabzon, Türkiye's environment minister Murat Kurum was asked how disagreements at COP31 would be settled between his country and Australia. His answer: "the final decision lies with the presidency of COP31."
Australia believes it runs the negotiations. Türkiye believes it runs the conference. Both are, on paper, correct. That is the arrangement COP31 begins under when it opens in Antalya on 9 November.
A Presidency Split Two Ways
The deadlock between Türkiye and Australia over hosting rights was resolved at COP30 in Belém through a structure the convention has never used before. Türkiye holds the formal COP Presidency, with Kurum as President. Australia's climate minister Chris Bowen takes a newly invented role, COP President of Negotiations.
The division of labour is real. Türkiye hosts in Antalya, manages logistics, opens and closes sessions and oversees the adoption of decisions. Australia convenes consultations, appoints co-facilitators, produces draft text and holds delegated authority over the substance. The pre-COP will be held in Fiji, with components in Tuvalu and Palau, which gives the Pacific a platform it would not otherwise have had.
The legal basis is thinner than the arrangement suggests. The President of Negotiations role does not exist in the UNFCCC draft rules of procedure. The modalities document handles conflicts by requiring consultation "until resolved to mutual satisfaction", which is diplomatic language for having no tiebreaker. Whether Australia's authority survives the closing gavel is also unclear.
For companies tracking the outcome, the practical consequence is that COP31 carries more procedural risk than a normal COP. A summit that spends its final night arguing about who is chairing is a summit that produces thinner text.
What Bonn Left On The Table
The June 2026 intersessional in Bonn, SB64, was the worst-tempered in several years. UN Climate Change executive secretary Simon Stiell warned that groups refusing to deliver commitments amounted to "a recipe for gridlock when we need all negotiating tracks to be moving in the fast lane."
The list of things pushed to Antalya is long.
The Global Goal on Adaptation text was deferred entirely under rule 16, with the reference to tripling adaptation finance still in brackets. AOSIS called the result completely unacceptable. Parties also deadlocked on whether the taskforce refining the 59 adaptation indicators adopted at COP30 should be technical or political, which sounds procedural and is not: whoever controls the taskforce controls what adaptation progress means.
The Mitigation Work Programme could not agree even minimal closing conclusions. The old split held, between parties who want it to drive emissions cuts and parties who want it to remain a forum for sharing experience.
Climate finance went nowhere. The new collective quantified goal agreed in 2024 sets 300 billion dollars a year for developing countries by 2035, and by June almost no developed country had pledged anything beyond 2025. Aid cuts mean public climate finance has probably fallen. The Article 9.1 work programme, meant to give space to the obligation on developed countries to provide finance, split over whether it covers public money only or mobilised private capital as well, and the G77 and China rejected the co-chairs' work plan outright. COP30 president André Corrêa do Lago used his own authority on 12 June to have Article 9 placed on the COP31 agenda, a move that was cheered and is not binding.
One thing did move. On 17 June parties agreed a package advancing the Belém-Antalya Mechanism for Global Just Transitions, covering terms of reference for its review and a list of items to develop. Governance, the role of non-party stakeholders and the financial architecture are all still blank.
The fossil fuel transition roadmap remains outside formal negotiations. Twenty-one countries and groupings submitted views, the same number that responded on deforestation. Small island states and the Environmental Integrity Group want it brought into the COP31 process. The Arab group and the large developing-country producers have said nothing, which is itself a position.
Carbon Markets Reach Balance Sheets Faster Than Anything Else At A COP
Article 6 is the part of the Paris architecture that translates into corporate accounting rather than national policy, and it has crossed from theory into operation.
The Article 6.4 Supervisory Body has adopted its first methodology and approved the first credits for issuance under the Paris Agreement Crediting Mechanism. Accreditation, activity registration and issuance processes now exist. The registry infrastructure is still being built out, and the Supervisory Body, Accreditation Expert Panel and Methodological Expert Panel continue to meet through 2026.
Two consequences matter for companies buying credits.
The first is that PACM creates a quality benchmark that voluntary market credits will be measured against, whether or not a buyer ever touches a PACM unit. When a sovereign-backed mechanism with corresponding adjustments and a published methodology exists, "we bought from a reputable registry" stops being a sufficient answer in an assurance conversation.
The second is the split between authorised and unauthorised units. Credits authorised for use toward another country's NDC carry a corresponding adjustment and command a premium. Credits used for voluntary corporate claims generally do not. Companies building offsetting into a net-zero plan need to know which they hold, because the two are not interchangeable and the price gap is widening. Five per cent of PACM issuance proceeds flows to the Adaptation Fund, which is worth knowing when modelling cost.
The Host's Own Carbon Market Is The Preview
Türkiye is not a bystander in this. Its first Climate Law was adopted on 2 July 2025 and published in the Official Gazette on 9 July, establishing the legal basis for a national emissions trading system. A Carbon Market Board chaired by the environment minister sits above it, the Directorate of Climate Change runs operations, and Energy Exchange Istanbul will handle the secondary market and registry.
The pilot phase is expected during 2026, with penalties reduced by 80 per cent while it runs and secondary legislation due by the end of 2027. Coverage is expected to resemble the EU ETS but has not been finalised.
Buried in the law is an authorisation to introduce a Turkish carbon border adjustment mechanism once allowance auctioning begins and domestic carbon costs rise, with the Ministry of Trade to set scope. Exporters who have spent two years building EU CBAM reporting should note that the same logic is now written into the law of the country hosting COP31, and that a second CBAM operating on different rules is a data problem long before it is a cost problem.
How A COP Outcome Becomes A Compliance Obligation
This is the chain that gets skipped in most COP coverage, and it explains why the answer to "what does COP31 mean for my reporting" is almost never immediate.
COP decisions bind governments, not companies. They shape nationally determined contributions. NDCs shape sectoral policy. Sectoral policy produces compliance markets, efficiency mandates and disclosure rules. The lag between a COP paragraph and a filing obligation is typically three to six years.
India is the clearest live example. Its NDC for 2031 to 2035 was approved by Cabinet in March 2026 and communicated in April: a 47 per cent cut in the emissions intensity of GDP by 2035 against a 2005 base, and 60 per cent non-fossil installed power capacity. Those are national numbers with no direct corporate obligation attached.
Underneath them sits the Carbon Credit Trading Scheme, which is now a compliance instrument. Obligations have been in force since fiscal 2025-26 for roughly 490 entities across seven sectors: aluminium, cement, chlor-alkali, pulp and paper, petroleum refining, petrochemicals and textiles. Targets were notified in two tranches, four sectors in October 2025 and three in January 2026, measured against a fiscal 2023-24 baseline and covering fiscal 2025-26 and 2026-27. Iron and steel and fertiliser are still awaiting final targets. Entities short of target buy and surrender carbon credit certificates.
That is what a COP outcome looks like four years downstream. Not a disclosure rule, a surrender obligation with a price on it.
What COP31 Will And Will Not Change For Reporting Teams
It will not change IFRS S1 or S2, ESRS, the GHG Protocol or any national disclosure rule directly. Those move on their own calendars, and conflating them with the UNFCCC process produces bad internal forecasting.
It will influence four things that eventually reach reporting.
Adaptation is the one to watch. If the GGA indicators are settled at Antalya and the tripling language survives, adaptation and physical risk move up the disclosure agenda within about two years, and the resilience sections of IFRS S2 and ESRS E1 reports start being read seriously rather than skimmed.
The just transition mechanism, if it gains governance and money, gives regulators and investors a vocabulary for workforce and community transition that currently exists mainly in ESRS S1 to S3 and in voluntary frameworks. Expect the questions before the rules.
Article 6 progress feeds directly into how credit use in corporate claims is judged, by assurance providers now and by regulators later.
And the finance tracks determine how much capital flows toward transition in developing economies, which for any company with an emerging-market value chain is the difference between a supplier decarbonisation plan that is fundable and one that is a spreadsheet.
Between Now And 20 November
Watch four things. Whether Article 9.1 survives on the formal agenda after Corrêa do Lago put it there. Whether the fossil fuel roadmap is pulled into negotiated text or stays presidency-driven. Whether the adaptation indicator taskforce is resolved as technical or political. And whether the two presidencies can produce a single cover decision without a public argument about who owns it.
Nothing on that list will change what your company files in 2027. All of it will shape what you are asked about in 2029, and the companies that read Antalya properly will be the ones that already know which of their disclosures are downstream of which negotiating track.
Position as of 22 September 2026. COP31 convenes in Antalya from 9 to 20 November 2026 and the agenda, presidency modalities and negotiating outcomes may all change before and during the session. Türkiye's ETS secondary legislation, India's CCTS targets for remaining sectors, and the Article 6.4 registry build-out were all incomplete at the time of writing. Confirm current requirements against the UNFCCC, your national authority, the Bureau of Energy Efficiency, and the relevant standard-setters, and take professional advice for your circumstances.
Sources
United Nations Framework Convention on Climate Change, COP31 Türkiye Presidency, Article 6.4 Supervisory Body, Australian Minister for Foreign Affairs, Legal Response International, Carbon Brief, Climate Home News, Climate Action Network Europe, International Carbon Action Partnership, Official Gazette of the Republic of Türkiye, Ministry of Environment, Press Information Bureau, India Nationally Determined Contribution 2031 to 2035, Council of the European Union, World Resources Institute
This article is intended for general professional information and does not constitute legal, financial, or investment advice.
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