Aviation in the EU ETS: ECJ clears the runway

Climate change does not conform to business, political or supervisory regime cycles– its adverse long-term impacts lie beyond such horizons. Ten years ago, when Mark Carney highlighted this paradox in his landmark Tragedy of the Horizons speech, climate change was not considered a financial stability risk. Today, European supervisory stress tests estimate up to €638 billion in banking losses over 8 years, while the European Central Bank (ECB) reveals that over 90% of eurozone banks face climate and environmental risks. A key question arises: Is the supervisors’ primary focus on greening the financial system sufficient in the face of rising risks, especially stranded assets? 

The climate and development finance gap is large and widening, as Official Development Assistance (ODA) declines and needs multiply. With shrinking fiscal space in vulnerable countries, solidarity levies are gaining attention as a predictable source of international finance. Launched at COP28 by Barbados, France, and Kenya, the Global Solidarity Levies Task Force (GSLTF) is the main initiative in this space.

“What agreement will the negotiators reach?” is the question that is usually on climate practitioners’ minds at this time of the year. However, this time, it is a new impetus that is needed, not another agreement. 10 years after the Paris Agreement, the Brazilian COP30 presidency has rightly shifted the focus to execution, making this edition “the implementation COP.” On financing, the objectives set at COP29 are clear: developing countries should receive $300 billion per year by 2035 from developed countries (NCQG), and mobilise $1.3 trillion per year from all actors. The newly published “Baku to Belém” roadmap proposes solutions to meet the targets. We now have objectives and a list of (theoretical) means to achieve them. How do we move to implementation?