By Carlos de Freitas, FMDV
As finance fights over Article 9.1, adaptation and Loss & Damage unfold under the Baku-to-Belém 1.3T Roadmap, cities and regions emerge as the missing link: country platforms, flow-alignment and locally led approaches offer new levers, but explicit subnational access is still to be won.
Meanwhile, Loss and Damage has moved from design to a first funding call under the new Fund, but without a dedicated window for cities and regions; developing countries are pushing for rapid, locally accessible support while national authorities remain the gatekeepers.
Climate finance
By the rest day, all finance tracks are formally open: joint COP/CMA contact groups are working on the Standing Committee on Finance (SCF), GCF, GEF, the Fund for Responding to Loss and Damage (FRLD), ex-ante finance reporting under Article 9.5, and a CMA dialogue on alignment of financial flows with Article 2.1(c).
On Article 9.1 and NCQG follow-up, the African Group, Arab Group, AILAC, GRUPO SUR and others are pushing for a dedicated political space: a stand-alone agenda item or work programme on implementing Article 9.1, an “action plan”, clear milestones for operationalising the new NCQG, and even a new quantified goal on adaptation finance. South Africa and Panama have asked to define legally what “provision” of finance means. Developed countries (Japan, UK, EIG, Norway and others) insist on treating Article 9 as a whole, emphasising voluntary contributions (Art. 9.2), “all sources of finance” and private-sector mobilisation (Art. 9.3) rather than a narrow focus on 9.1.
On the Baku-to-Belém Roadmap to 1.3T, the roadmap is now the main political frame: 36 Party submissions fed into a text that aims to move from the NCQG’s “at least USD 300bn” by 2035 to at least USD 1.3tn annually for developing countries by 2035. Developing blocs use the process to demand more grant-based and non-debt instruments, debt relief and clearer accountability, while developed countries stress private capital, “all sources” and broader contributor bases.
On Adaptation and Loss & Damage, tripling adaptation finance and establishing a specific adaptation-finance goal are being fought across several rooms (GGA indicators, NAPs, NCQG follow-up). Mauritania, for instance, has called for a dedicated adaptation finance window under the Financial Mechanism.
The FRLD has launched a first call for proposals (“Barbados Implementation Modalities”) with USD 250m for grants of USD 5–20m, while a COP30/CMA7 draft guidance text is under negotiation; this is tiny compared to estimated needs of nearly USD 400bn in 2025 alone.
First week conclusion
For subnational and locally led action, the formal finance texts still barely mention cities or regions, but week-one decisions open hooks: a Presidency workshop on local communities recommended a separate window for local communities in the UNFCCC locally-led adaptation initiative and “direct and simplified access modalities” for Indigenous Peoples and local communities under the GCF, Adaptation Fund and other funds.
This gives the LGMA constituency concrete language to argue for devolved, direct-access windows and tracking of finance reaching local and regional governments within the broader 1.3T and NCQG architecture.
For the LGMA constituency, the opportunity might lie in the new focus on country platforms, system-wide flow alignment, “local support organisations” (to Climate Action Implementation) and people-centred implementation (a “Just Resilience” pillar), even though cities and regions are not yet explicitly named in the core finance texts.
The Presidency framing COP30 as a shift from negotiation to implementation of the Paris policy cycle could also be a sign of a disruptive COP chapter for institutionalization of a new multilateral (and multistakeholder) action space.
Loss & Damage
Loss & Damage discussions in week one centred on three tracks: the start-up phase of the Fund for Responding to Loss and Damage (FRLD), the third review of the Warsaw International Mechanism (WIM) and its Santiago Network, and guidance from COP/CMA to the FRLD Board.
The Presidency’s week-one summary complements this picture by signalling a collective “commitment to accelerating growth of financing for reducing loss and damage” as part of the Article 9.1 and NCQG follow-up package, framing COP30 as a shift from negotiation to implementation of the Paris policy cycle.
On day one, the FRLD formally launched the call for funding requests for its start-up phase, the Barbados Implementation Modalities (BIM): an initial USD 250m envelope for grants of USD 5–20m, with a six-month application window starting 15 December 2025 and approvals expected from July 2026.
BIM is framed as bottom-up and country-led, but for this phase access is through national governments via direct budget support, with the Board still to develop policies on rapid disbursement and small-grants schemes for communities.
Negotiations on the FRLD report and guidance text revealed sharp divides. G77/China, LDCs and AOSIS pressed to: anchor guidance in paragraph 16 of the NCQG decision (tripling public flows from UNFCCC funds by 2030), accelerate work on rapid-response and small-grants policies, and guarantee direct and simplified access for all vulnerable developing countries.
Several developed countries (EU, UK, Canada, Australia) questioned the need for detailed COP guidance at this early stage and resisted explicit NCQG cross-references.
The third review of the WIM produced an informal note with emerging convergence on a State of Loss and Damage / Gap Report, stronger technical-assistance functions and coordination between WIM, the Santiago Network and FRLD, but with unresolved issues on integrating loss and damage into NDCs, GST follow-up, scaling finance, and recognising the ICJ Advisory Opinion and human-rights language.
By the end of week one, pledges remain minimal, about €20m from Spain to the FRLD and CHF 1m from Switzerland to the Santiago Network, against estimates that developing countries may need USD 395bn in 2025 alone and over USD 700bn per year across the loss-and-damage landscape.
For subnational governments, the BIM call and the guidance fight are therefore critical. The Presidency note recognises the “important role of … regional and local support organizations in supporting the implementation of climate action”, which gives LGMA a hook to argue that any accelerated growth of loss-and-damage finance must be channelled through territorial institutions and locally led mechanisms, not only central treasuries.
In this first BIM phase, cities, regions and local facilities can only benefit if national authorities and FRLD guidance deliberately route programmes through subnational development banks, territorial funds and local grant schemes, while future small-grant and direct-access windows are designed with local governments and communities in mind.
