COSP11: Climate Action Accountability Pathways

The National Anti-Corruption Commission

National Anti-Corruption Commissioner the Hon Paul Brereton AM RFD SC delivered this speech at the eleventh session of the Conference of the States Parties to the United Nations Convention against Corruption (COSP11) on 16 December 2025 in Doha, Qatar.

Thank you, to our colleagues at the UNODC for organising this event, on an issue of vital importance for our planet and every one of its inhabitants: accountability pathways for climate action.

Australia will assume the role of President of Negotiations in the lead up to and at the 31st Conference of Parties of the United Nations Framework Convention on Climate Change in November 2026. There will be a particular focus on climate financing, including a special session and pledging for a Pacific Resilience Facility - a Pacific-led fund to support Pacific climate responses.

Global investment in clean energy projects now exceeds $2 trillion annually. This must and will grow. This expenditure is essential to the future of the planet and humanity, but it is also highly vulnerable to exploitation and diversion by corrupt actors.

Let us recall that in 2019, COSP8 recognised in resolution 8/12 the role that corruption can play in crimes that have an impact on the environment. So too has the General Assembly, at its special session against corruption in 2021, and the Conference of the Parties to the United Nations Convention against Transnational Organized Crime.

Corruption in the environmental sector has been a strategic corruption priority area for the National Anti-Corruption Commission since our establishment.

Reasons why this is so inform what accountability measures are required to avoid or mitigate them. The reasons include:

  • the enormous amounts involved, which means that degradations can appear insignificant and difficult to detect

  • the political imperative of delivery - and of speedy delivery. This means that controls and oversight of expenditure are minimal or immature

  • many aspects of detail are technical and not easily understood by those with oversight. Corrupt actors can exploit this lack of understanding. In particular, carbon markets are a significant component of climate finance. Their abstract nature makes them fertile ground for bribery, false claims of compliance, and greenwashing

  • the complexity and opaqueness of climate finance arrangements creates opportunities for overpricing, market distortion and misallocation. Many projects are in the nature of construction projects, often involving major infrastructure. These may not be tested by the forces of nature for years. Unscrupulous suppliers can deliver substandard work and materials which, when they come to be tested by the force of nature years or decades later, may fail with catastrophic results

These vulnerabilities point to the requirement for accountability for climate finance, throughout the chain from allocation to delivery. I suggest that the following elements are important aspects of accountability:

  • a clear and enforceable legal basis for the application and use of funds

  • a transparent and traceable flow of funds from allocation to delivery

  • minimise the levels and agencies through which funds flow and ensure there are internal and external controls at each level

  • above all, vigilant quality assurance at the point of delivery, to ensure the product is fit for purpose.

I look forward to hearing the suggestions and remedies proposed by the other panel members.

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