ICC calls on climate ministers ahead of COP31 to set the conditions for business to deliver

Dear Ministers, 

Since Belém, we’ve all heard, countless times, that this must be the “COP of implementation, COP of delivery”. The global business community wholeheartedly agrees. But delivery cannot remain a slogan.  

Our message is simple: for COP31 to succeed, it must firmly place economic strategy at the centre of political ambition and it must lay the building blocks for a master delivery plan – that advances climate action, prosperity, competitiveness, and energy security all at once – and sends the policy and market signals business needs. 

Against an exceptionally challenging geopolitical and economic backdrop, with heightened instability, energy shortages and maritime trade disruptions threatening what we have warned could become “the worst industrial crisis in living memory”, the need to get these conditions right has rarely been more urgent. Secure, efficient and resilient energy systems must be at the heart of the response.  

From a business perspective, implementation becomes real only when climate policy is translated into economic value: stable policies, credible incentives, harmonised standards, investable projects, functioning markets and access to finance are the key enablers. 

The Action Agenda, voluntary efforts, coalitions and business leadership can take us far, but the future of climate action at scale required ultimately depends on clear, credible and sustained policy signals that only your governments – through the UNFCCC negotiated process, can provide. 

To that end, we urge you to focus on the following three priorities in Antalya: 

1. Accelerate the clean energy transition, putting electrification and energy efficiency at its heart. Keeping 1.5°C within sight, and limiting the severity and duration of any overshoot, must remain our overriding priority. Electrification is one of the central enablers and the ambition for a global 35% electrification target by 2035 is welcome. But more important than setting a global goal – is building the implementation capacity – energy systems that can support a rapid scale-up in renewable energy and meet rising electricity demand, while remaining reliable, affordable and competitive for households and businesses. Setting a robust, integrated policy agenda that creates the conditions for investment and puts focus on smart system design, timely grids and connections, stronger incentives and stable regulation should be the priority. Energy efficiency, one of the fasted and most cost-effective ways to reduce emissions, while strengthening energy systems, must be at the core of that agenda, as must be the deployment of all low emission solutions and technologies.  
   The next phase of the energy transition will be judged not by capacity deployed alone, but by the delivery at the pace required and resilience of the energy systems it delivers.   

2. Make adaptation a political and economic priority: Public finance must continue to lead where adaptation measures cannot generate commercial return, but it cannot close the gap alone. Let us be clear: if we are to make progress on the Global Goal on Adaptation and come anywhere near the Belém promise to triple adaptation finance, the Belém indicators must speak to the real economy and provide robust methodologies and usable information that help calculate the return on investments and support real-world decision-making.  
   
   We encourage you to think about how the private and financial sector may best be harnessed as a partner in technical work ahead and kick start a global dialogue bringing together development banks, insurers, commercial lenders, and investors – to work together to scale funding for adaptation-aligned investments in vulnerable sectors and regions.    

3. Set a new climate finance trajectory. Finance is the fuel to any credible transformation, yet risk, regulatory and systemic bottle necks, continue to hold back investment where it is most needed.  
   We have watched with great concern the finance debate at past COPs that have become increasingly entrenched, at the risk to become detrimental to the whole process. The NCQG and Baku-to-Belém Roadmap now provide an opportunity – through the new Climate Finance Work Programme – to turn the page, moving towards a clear delivery plan on finance that addresses public finance needs while placing a clear emphasis on mobilising private finance at scale. 
   Changing trajectory requires political will to take on the real bottlenecks – regulatory and operational barriers in the systems itself. Targeted clarification of prudential rules affecting clean energy and infrastructure projects, clear targets to the catalytic deployment of private capital by multilateral development banks, and a pathway to recalibrate emerging market credit rating through better risk data. These are the calls and signals a robust finance delivery plan must contain. 

Finally, our firm view remains clear: robust carbon markets, including under Article 6 are part of the key solutions we need for scale, supported by legal and contractual certainty, harmonised carbon accounting, standards and full interoperability in carbon border measures.  

Taken together, these are the priorities for delivery: projects financed, grids built, resilience in place. That cannot happen without business at the table – not as an observer, but as a co-architect of solutions.  

Through the COP31 Business Forum convened by The Union of Chambers and Commodity Exchanges of Türkiye (TOBB) and the incoming COP31 Presidency, and with our support as international business partner as well as ICC’s forthcoming recommendations on electrification, energy efficiency and climate finance, we stand ready to support a successful COP31.  

We look forward to continuing the conversation in Antalya, including at the COP31 Business and Investment Summit on 12–13 November. 

Set the conditions, and business can invest, build and deliver. 

Yours faithfully, 

John W.H. Denton AO 

Secretary General
International Chamber of Commerce