When delegates gather in Antalya, Turkey, from November 9 to 20 for this year’s United Nations Climate Change Conference of the Parties, known as “COP31,” they will find themselves at the “COP of Implementation.” While the concept of implementation sounds comparatively simple, we expect this year’s COP to reflect a full range of complexities on the formal United Nations negotiations side and continuing widespread interest from the private sector and civil society.

For the COP’s Presidency – hosted this year by Turkey’s Environment Minister and responsible for shaping much of the conference’s agenda – implementation means meeting the goals for addressing climate change by setting measurable targets and working out how to operationalize the emissions reduction and financing commitments countries have long since made, including climate finance, adaptation, a new mechanism for a just transition, the future of the mitigation work programme, and the launch of the second Global Stocktake. But much of the momentum in Antalya will be outside the formal text, in voluntary pledges, investment platforms, and business-led initiatives, giving companies a direct hand in shaping what implementation looks like, particularly as issues such as surging energy demand posed by the expansion of Artificial Intelligence gain greater prominence on the international stage. What comes out of COP31 will shape the energy markets, trade rules, capital flows, and disclosure expectations those same companies operate within.

The Expanded Role of Business at COP31

Two forces increase the critical role that business will play at COP31. The first is the absence of the United States. COP31 is the first summit since the U.S. withdrawal from the Paris Agreement took effect in January 2026, and the United States will leave the UN Framework Convention on Climate Change itself, the first country ever to do so, on February 27, 2027. While a congressional delegation organized by the Sustainable Energy and Environment Coalition Institute plans to meet with policymakers, civil society groups, and business leaders, and state and local leaders will attend under the America Is All In coalition, the U.S. will not have a formal delegation.

For U.S. companies, the absence of their government from the negotiating table does not mean absence from the consequences. U.S. exporters face carbon border measures regardless of Washington’s posture, multinationals face transition-planning and disclosure expectations from other jurisdictions, customers, and investors, and many of the investment opportunities discussed in Antalya are open to U.S. developers, equipment suppliers, and financial institutions. Companies that engage through business forums, coalitions, and subnational partnerships will have a voice in Antalya even without an official governmental delegation.

The second force is the need for capital. The climate finance goal adopted at COP29 calls on all actors to scale up finance for developing countries to $1.3 trillion a year by 2035. Roughly half of that, about $650 billion, is expected to come from cross-border private finance. The opportunity is large: global energy investment is expected to reach $3.4 trillion in 2026, with about $2.2 trillion going to clean energy, grids, storage and electrification, nearly twice the $1.2 trillion directed to fossil fuels. The Presidency has made the point structurally, scheduling the COP31 Business and Investment Summit alongside the Leaders’ Summit and tasking its Private Sector Envoy with presenting a business roadmap prepared by more than 700 business leaders.

Four Business Priorities at COP31

1. Clean Energy Transition and Electrification

The Presidency’s flagship 35-by-35 Global Electrification Pledge would raise electricity’s share of final energy consumption from about 23% today to 35% by 2035. Australia’s Chris Bowen, the COP31 President of Negotiations, calls electrification “a practical way to lower energy bills, reduce emissions, and strengthen energy security,” a framing with broad appeal amid volatile oil and gas prices. If countries sign on, most of the build-out will fall to the private sector: utilities and transmission developers, grid equipment and storage manufacturers, EV and heat pump supply chains, and data center developers. For companies that buy power, the same push affects how quickly projects connect to the grid, how power is procured, and what industrial electricity costs.

Still, grids and storage have not kept pace with renewables, and the cost of capital remains a major barrier in emerging economies. Artificial intelligence makes these challenges more acute. The IEA estimates that data centers used about 415 terawatt-hours of electricity in 2024 and expects that figure to more than double by 2030; in the United States, data centers’ share of electricity use reached 4.7% in 2024 and could reach about 11.8% by 2030. The voluntary Antalya AI Pledge responds by inviting business commitments such as disclosing energy data and powering data centers with clean energy. A companion AI for Clean Technologies Initiative provides opportunities to develop AI-enabled pilots in areas such as smart energy and connect them with industry partners and investors, reflecting AI’s potential to forecast renewable output, balance grids, and reduce curtailment.

In the formal UN negotiations, the questions are whether the 35-by-35 goal makes it into the negotiated outcome or remains a voluntary pledge; whether France’s push for a binding COP decision tying electrification to cleaner power gains support, given that the pledge does not specify how the additional power is generated; and whether parties agree to continue the mitigation work programme, the main formal venue for emissions-reduction discussions, beyond 2026.

2. Industrial Competitiveness and Decarbonization

Green industrialization is one of the Presidency’s ten Action Agenda priorities. The Antalya Green Industrialization Compact will launch alongside the talks, building on Turkey’s Industrial Decarbonization Investment Platform, launched with the European Bank for Reconstruction and Development (EBRD) in 2024, which aims to deploy €5 billion of investment by 2030 to decarbonize the steel, aluminum, cement and fertilizer sectors.

The more contentious industrial issue is trade, and in particular the EU’s Carbon Border Adjustment Mechanism, or CBAM. Under it, European producers pay for their emissions under the EU Emissions Trading System, and CBAM charges EU importers of steel, aluminum, cement, fertilizers, hydrogen and electricity a matching price for the carbon embedded in those goods. CBAM is important at COP31 because many developing countries see it as a unilateral trade measure that shifts the cost of Europe’s climate policy onto their exporters. China wants COP31 to address green-technology “protectionism” and the African Group has asked for a formal agenda item on trade.

Formally, trade is not on the COP31 agenda; it is confined to a dialogue held at the June Bonn sessions through 2028. Still, this year’s mitigation work programme topic is industry, and the June Bonn talks ended without agreed text, so negotiators will arrive in Antalya without a consensus draft. The other question is whether CBAM and similar measures resurface in the just transition mechanism negotiations affecting developing measures, under the response measures agenda item that covers cross-border impacts of climate policies, or in the final negotiated text, since developing countries have pushed for a standing trade agenda item.

3. Climate Finance and Carbon Markets

The COP29 goal, developed at the Conference in Baku, commits developed countries to take the lead in delivering at least $300 billion a year in climate financing by 2035. Since then, there has been some momentum: in 2024, developed countries provided and mobilized $136.7 billion, up from $61.8 billion just ten years prior, and multilateral development banks have estimated that they will provide $120 billion a year by 2030. The harder task is mobilizing the private capital behind the broader $1.3 trillion goal. The tools for doing so include guarantees and other risk-sharing instruments, blended finance, local currency lending and “country platforms” that bring public and private finance together behind national transition plans. Turkey’s Renewable Energy Acceleration and Clean Transition Platform (REACT), which aims to facilitate up to $100 billion of clean energy investment, is one such example. For developers, lenders, insurers and equipment suppliers, these structures are the entry point to MDB-backed projects in emerging markets.

Additionally, carbon markets are now operational and looking to scale. The Paris Agreement’s crediting mechanism issued its first credits in February 2026, and country-to-country trades under Article 6.2 have been under way since the first transfer, from Thailand to Switzerland, in December 2023, so integrity and authorization rules will increasingly determine which credits hold their value. Financial institutions will also be asked to lower the cost of capital in emerging markets, price climate risk, and show how their own transition plans hold up.

In the negotiations, watch who is expected to pay. Developing countries want the new climate finance work programme to focus on developed countries’ legal obligation to provide finance, while developed countries want it to cover the broader finance provisions, which also encourage contributions from other countries and the mobilization of private capital. Keep an eye on whether parties make progress on the Paris Agreement’s goal of making all financial flows consistent with low-emissions, climate-resilient development. And notice whether parties agree on how to fund the registries and reporting systems that countries need to trade carbon credits with one another, a decision parties at the last COP in Belém slated for adoption in Antalya.

4. Fossil Fuel Transition

In Dubai in 2023, nearly 200 countries agreed for the first time to the goal of “transitioning away from fossil fuels in energy systems.” In Belém, more than 80 countries backed a roadmap to implement that commitment, yet the final agreement failed to explicitly mention fossil fuels after opposition from major oil producers. Exporters argue the target should be emissions, rather than fuels. Large emerging economies resist prescriptive language, the poorest countries want finance and flexibility, and small island states and the EU want firm timelines.

With consensus out of reach, UN leadership moved the discussions outside the formal negotiations in order to attempt to make some progress on this contentious issue. Brazil’s COP30 Presidency released a voluntary roadmap on November 3 that urges every country to “start now,” using a common framework to assess its exposure to fossil fuels and its readiness to transition across energy demand, energy supply and the broader economy, and proposes a collective agenda to accelerate coordinated action through 2033. In April, 57 countries met in Santa Marta, Colombia, for the first conference dedicated to transitioning away from fossil fuels, with a second planned in Tuvalu, co-hosted with Ireland, in early 2027.

That work will also feed into the second Global Stocktake, the Paris Agreement’s five-year review of collective progress, which begins in Antalya. The stocktake assesses whether countries’ combined emissions reduction commitments, measured against actual global emissions trends, put the world on track to meet the Paris Agreement’s collective temperature goals, and it also reviews progress on adaptation and finance. A technical assessment starts in June 2027, and the process concludes in November 2028, in time to inform the next round of national climate plans due in 2030. The first stocktake, completed in Dubai in 2023, found that collective efforts were not on track to meet the Paris emissions target goals and produced the general commitment to transition away from fossil fuels; the second will measure what has been delivered since then.

For business, the absence of specific negotiated international language does not mean an absence of expectations. These processes give investors, lenders, regulators and customers benchmarks for judging the transition plans of oil and gas producers, utilities, heavy industry, and the financial institutions that fund them. In the negotiations, watch whether any fossil fuel language reaches the final negotiated text; how the stocktake’s launch frames the gap between current commitments and the Paris goals, including progress on the Dubai commitment; and how parties settle the functions of the new just transition mechanism.

Looking Ahead

COP31 is unlikely to produce a breakthrough agreement. Its significance will lie in whether implementation is made to be measurable: signatures on the electrification pledge and a clearer link to clean power, a credible start to the second Global Stocktake, finance that moves capital rather than restating goals, and a sense of whether the fossil fuel debate can be bridged between the formal process and the coalitions forming around it. It is increasingly clear that the climate agenda now runs through markets, supply chains, and investment decisions in the United States and globally, with or without full government participation.

The UN Climate Conference organizes its activities around daily themes – illustrating the breadth of climate effects and opportunities.  Of COP31’s thematic days, those likely to be most relevant for business are Energy and Transport (November 10), Finance and Trade (November 13), Science, Industry and Technology (November 16), and “İmece”: Enhancing Implementation through collective actions (November 19).

For businesses that will be on the ground in Antalya, the following pavilions and events are particularly worth a look:

  • COP31 Business and Investment Summit (November 12–13, Blue Zone). Organized by the COP31 Private Sector Envoy, the Union of Chambers and Commodity Exchanges of Turkey.
  • World Climate Foundation Impact Weeks (November 9–20). An Implementation Hub in the Blue Zone, an Investment COP with the Milken Institute, and the 17th World Climate Summit on November 15.
  • IETA BusinessHub (Blue Zone, November 9–20). The International Emissions Trading Association’s programming on carbon markets, technology and climate finance.
  • Sustainable Innovation Forum (November 10–11). Climate Action’s flagship forum, aligned with the 35-by-35 target, held at the Climate Action Innovation Zone, an independent venue with its own registration that does not grant access to the Blue or Green Zones.
  • Global Sustainable Insurance Summit (November 13–14). Convened by UNEP and the Insurance Association of Türkiye, focused on climate resilience.
  • America Is All In Pavilion (opening November 9; main programming November 12–16). Hub for U.S. state, local and business engagement in the absence of a federal delegation.

Covington will have representation on the ground in Antalya and will publish a post at the close of COP31 with on-the-ground insights and what the outcomes mean for business.

Gabriela Nalvio Melillo, Associate, contributed to this blog post.

Photo of Kevin Poloncarz Kevin Poloncarz

Kevin Poloncarz co-chairs the firm’s Environmental and Energy Practice Group, Energy Industry Group and Sustainability Practice.

Kevin is ranked by Chambers USA among the nation’s leading climate change attorneys and California’s leading environmental lawyers and by Chambers Global among the top climate change…

Kevin Poloncarz co-chairs the firm’s Environmental and Energy Practice Group, Energy Industry Group and Sustainability Practice.

Kevin is ranked by Chambers USA among the nation’s leading climate change attorneys and California’s leading environmental lawyers and by Chambers Global among the top climate change lawyers, with sources describing him as “exceptional,” “a superb attorney,” and “one of the most gifted advocates in this space in the country.”

He represents electric utilities, financial institutions, investors and companies in policy, litigation and transactional matters concerning emission-reduction strategies, power and carbon markets, carbon dioxide removal (CDR) technologies, carbon capture, utilization and storage (CCUS), and low carbon fuels.

Kevin convenes the Clean Energy Group, which consists of some of the nation’s largest public- and investor-owned utilities and independent generators and focuses on federal and state environmental policy efforts affecting the power sector.

Photo of Gary S. Guzy Gary S. Guzy

Gary Guzy brings over forty years of experience in environmental law, regulation, and public policy. He provides counsel to industry leaders in the transportation, energy, technology, and consumer sectors on emerging environmental and clean energy issues – handling prominent regulatory comments, environmental litigation…

Gary Guzy brings over forty years of experience in environmental law, regulation, and public policy. He provides counsel to industry leaders in the transportation, energy, technology, and consumer sectors on emerging environmental and clean energy issues – handling prominent regulatory comments, environmental litigation, enforcement resolutions, and major project developments. He is skilled at creating strategic partnerships that bring together diverse groups to resolve challenging public policy controversies through close work with industry and environmental community leaders. Gary co-chairs the firm’s Energy Industry Group.

Gary served as Deputy Director and General Counsel of the White House Council on Environmental Quality (CEQ). In this position, he helped develop and guide the Obama Administration’s environmental, public health, and clean energy agenda, bringing business insights to government policy and coordinating policy across government agencies. He spearheaded negotiations that achieved the Obama Administration’s agreement to double motor vehicle fuel efficiency standards and significantly cut greenhouse gas emissions with the support of automobile manufacturers, states, labor unions, environmental and consumer groups, and Congress. Gary also led CEQ’s efforts to modernize permitting and environmental review under the National Environmental Policy Act, and counseled federal agencies on how to fulfill their NEPA obligations for dozens of high profile decisions and assisted in resolving NEPA controversies at numerous complicated sites.

Gary served as General Counsel of the U.S. Environmental Protection Agency and Counselor to the EPA Administrator during the Clinton Administration. He was a member of the Administrator’s senior policy team, setting regulatory, legislative, and communications strategy. He led efforts to design regulatory approaches to protect children’s environmental health, develop and defend new air quality and motor vehicle standards, defend EPA from Congressional oversight investigations, and protect iconic ecosystems such as the Everglades and Yellowstone National Park. He also authored climate change opinions that were later ratified by the U.S. Supreme Court in its landmark decision finding that greenhouse gases are pollutants under federal law.

Gary has also served as the chief legal officer, sustainability officer, and climate strategist for a variety of business organizations.