Key messages

• Two tracks: “climate finance” (Art. 9 provision and mobilisation) and “financing” (Art. 2.1(c), markets, access, MDBs). The EU pushes the centre of gravity to the second.
• The hardest fight is CMA 11(g), the Climate Finance Work Programme “including on Article 9.1.” The EU rejects a 9.1-only scope. The Economic and Financial Affairs Council (ECOFIN) even names the programme without the 9.1 reference.
• The ECOFIN conclusions of 9 October are the EU’s real finance mandate. Compared with 2024 and 2025, they are shorter and more defensive: competitiveness and fiscal caveats in, levies out, fossil language softer, no EU figures on adaptation or loss and damage.
• What holds: the USD 1.3 trillion call, “at least” tripling adaptation finance by 2035, Art. 2.1(c), MDB reform, and access to finance.
• The Environment Councils add little on finance: none in June; in October, six paragraphs (down from eight for COP29), with the political weight on mitigation.

Finance and financing on the COP 31 agendas

The agendas mix three kinds of items: climate finance in the strict sense (provision and mobilisation under Art. 9 and Convention Art. 4.3, the funds and the collective goals); financing in the broad sense (aligning all flows, carbon markets, access); and the financing of the UNFCCC itself.

On climate finance, the new and most contested item is CMA 11(g), the Climate Finance Work Programme (CFWP) “including on Article 9.1 in the context of Article 9 as a whole.” Outputs of the CFWP are due at COP 32 in November 2027. Alongside it run the long-term finance item (COP 8(a), the third report on the USD 100 billion goal and the loans-versus-grants accounting dispute), guidance to the GCF, GEF, and the Fund for responding to Loss and Damage (FRLD) (COP 8(c)–(e) / CMA 11(b)–(d)), the Adaptation Fund, the review of the Financial Mechanism, and the Standing Committee on Finance with its Biennial Assessment of flows. Guidance to the FRLD is the only formal item on loss and damage finance.

On financing, the key item is CMA 11(f) on Art. 2.1(c) and its complementarity with Art. 9. Finance is also embedded in the just transition mechanism (CMA 5), Article 6 markets (CMA 16), and the adaptation indicators under the Global Goal on Adaptation (CMA 9(a)). The funding of the Art. 6.2 infrastructure and the budget concern the regime itself.

Equally important is what has no agenda item. New Collective Quantified Goal on Climate Finance (NCQG) implementation and the Baku to Belém Roadmap to USD 1.3T will be fought over through 11(g), the Standing Committee reports, and the Presidency-led cover decision. The presidency’s Access to Finance Declaration and Action Plan sits in the non-negotiated Global Climate Action Agenda. Supplementary agenda requests remain possible by 9 November.

EU positions, with a focus on ECOFIN (9 October 2026)

The finance ministers’ conclusions set the EU line. They frame climate action as a driver of “competitiveness, innovation, and energy security” and note that the EU remains the largest contributor “despite fiscal and geopolitical challenges.” Their main elements:

• Goals: a commitment to all NCQG elements, including USD 300 billion by 2035; the Roadmap is only “noted;” COP 31 must preserve “the integrity of previously agreed outcomes,” a clear signal against reopening the NCQG.
• Contributor base: broadening is “a necessity,” and all countries “with the financial capacity” must step up. The EU’s work programme submission adds that there should be no quotas or 9.1 sub-targets, and that the USD 300 billion goal is not a quantification of 9.1.
• Delivery: developed countries provided and mobilised USD 132.8 billion in 2023 and 136.7 billion in 2024, so growth slowed from 14.6% to 2.9%. EU figures for 2025 are still to be endorsed before COP 31.
• Adaptation and loss and damage: support for “at least” tripling adaptation finance by 2035, but without a baseline; a welcome for the FRLD’s allocation floor for SIDS and LDCs, while the EU asks for no COP guidance to the FRLD this year.
• Financing: Art. 2.1(c) is a “domestic and international imperative,” qualified by a “balanced approach” on energy security, affordability, and cost efficiency. Fossil subsidy phase-out is subject to legal “derogations,” there is concern about an MDB slowdown, and innovative sources of finance are limited to carbon markets, debt swaps, guarantees, and bonds.

How the ECOFIN line has moved since COP29

Read across three years, the conclusions move from designing a goal (2024) to claiming delivery (2025) to defending what exists (2026). The text shrank from 17 to 16 to 13 paragraphs, and the tone shifted from science-led urgency to efficiency and then to competitiveness and fiscal caution. The changes are clearest on six points:

• Obligation: in 2024, public finance was “at its core” and developed countries were to “take the lead.” Neither formula survives in 2026, which speaks of “all sources.” The contributor base moves from “a prerequisite” (2024) to “a necessity” (2026).
  
• Adaptation: the target moves from doubling by 2025 to “at least” tripling by 2035. In 2025, the EU still quoted its own 75% increase over 2019–2023; in 2026, there is no EU figure and no word on whether the doubling was met.
  
• Loss and damage: the EU’s share of pledges to the FRLD (“over two thirds” in 2024, about 68% in 2025) is no longer cited.
  
• Fossil fuels: from “climate finance must not be used for fossil fuel related activities” and a call on MDBs to phase out fossil finance (2024), to fossil financing being merely “a major obstacle,” with caveats on subsidies and no MDB call (2026).
  
• Innovative sources: the 2025 openness to levies, including a reference to the Global Solidarity Levies Task Force, is gone. Only market and debt instruments remain.
  
• EU figures: public climate finance rose from EUR 28.6 billion (2023) to EUR 31.7 billion (2024), mobilised private finance from EUR 7.2 billion to EUR 11 billion. Growth came mostly from private mobilisation (+53%) rather than public money (+11%). The 2025 figure is pending.

The last two Environment Councils

The 25 June Council adopted no COP 31 conclusions. The Cyprus presidency took stock of efforts to strengthen the EU’s negotiating position (unity, a multi-annual “COP vision,” climate diplomacy), with no finance content.

The 12 October Council adopted the COP 31 conclusions. Their finance section (paras 27–32) recalls the ECOFIN text, as in 2024 and 2025, but its own content keeps shrinking: eight paragraphs for COP 29, seven for COP 30, six now. The dedicated loss and damage paragraphs of 2025 are gone. Instead, the political centre is mitigation: the 1.5°C overshoot, the transition away from fossil fuels, and a call for a “mitigation space” in the negotiations. The same Council debated the Emissions Trading System (ETS) review, including international credits, which links domestic choices to Article 6 demand.

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What to expect from the EU in Antalya

On the evidence of the Council texts and submissions, the EU may arrive with a defensive finance position and an offensive mitigation narrative. In practice this means:

• No new money on the table. The EU will point to its record as the largest contributor and to the NCQG but is unlikely to announce new collective or EU-level pledges.
• Firm resistance on Article 9.1. It will block a 9.1-only reading of the CFWP and any quotas or sub-targets while accepting procedural steps that keep the programme moving towards COP 32.
• Insistence on a broader contributor base. This will be the EU’s central ask in every finance discussion and its main condition for further ambition.
• Linkage between finance and mitigation. Movement on finance language is likely to be paired with demands on mitigation ambition and the transition away from fossil fuels.
• Activity on “financing” rather than “climate finance.” Expect engagement on Art. 2.1(c), access to finance, MDB reform, and the Presidency’s Access to Finance Declaration and Action Plan, which are low-cost areas where the EU can show results.
• A low profile on loss and damage and adaptation figures. The EU will support tripling adaptation finance in principle but avoid baselines or burden-sharing, and will leave the FRLD to its Board.

Key sources

• ECOFIN conclusions for COP31, 9 Oct 2026 (ST 14090/26)
• ECOFIN conclusions for COP29 (ST 14288/24) and 2023 figures (ST 14567/24)
• ECOFIN conclusions for COP30 (ST 13732/25) and 2024 figures (ST 14484/25)
• Environment Council conclusions for COP31, 12 Oct 2026 (ST 14250/26)
• CMA8 and COP31 provisional agendas (FCCC/PA/CMA/2026/1; FCCC/CP/2026/1)
• EU submission on the climate finance work programme, 16 Sept 2026

Acknowledgements

Clima Trust —formerly SLYCAN Trust— works at the global, regional, and national level to foster transformative action towards climate resilience, sustainable development, and innovative solutions. This briefing is an output of our EU Work Programme. Find out more about the work programme here.