What the Monitoring Framework Still Can’t See

This article was originally published by ECO, during the SBSTTA 28 meeting of the UN Convention on Biological Diversity.

As SBSTTA-28 considers both the Global Review of collective progress and the further development of the monitoring framework for the Kunming-Montreal Global Biodiversity Framework (KMGBF), delegates face an important but easily overlooked question: What aspects of implementation are actually being made visible?

The Framework rightly seeks to monitor biodiversity finance, harmful incentives and corporate disclosure. Yet a critical blind spot remains. It still provides only a limited ability to assess whether Parties are progressively implementing Target 14 by aligning public and private activities, and fiscal and financial flows, with the goals and targets of the Framework. One important reason is that we continue to have only a partial picture of the much larger public and private financial flows that continue to drive biodiversity loss.

This matters because counting more money labelled for biodiversity cannot, on its own, tell us whether financial systems are becoming more consistent with the goals of the Framework. Even substantial increases in biodiversity finance may not correspond to overall progress if much larger financial flows continue to incentivise ecosystem conversion, deforestation and environmentally harmful production.

Target 14 commits Parties to progressively align public and private activities, and fiscal and financial flows, with the goals and targets of the Framework. Achieving that ambition requires more than mobi-lising additional finance. It also requires visibility of the financial flows that remain inconsistent with biodiversity objectives, together with the policy and regulatory measures being used to address them.

Target 15 has rightly increased attention on corpo-rate and financial institution disclosure. But disclosure is not an outcome in itself, and selective disclosure risks obscuring what is actually happe-ning. Monitoring should therefore help us understand not only whether institutions disclose biodiversity-related information, but whether those disclosures support better decision-making, meaningful reductions in harmful impacts and progress towards the objectives of the Framework.

The technical challenges are real, but they are not insurmountable. Civil society, researchers and financial analysts already demonstrate that it is possible to identify significant financing associated with high-risk sectors using publicly available data. While these approaches are necessarily incomplete, they show that improved monitoring is feasible, and that many remaining data gaps reflect transparency and policy choices rather than technical impossibility. The question is therefore becoming less whether such monitoring is possible, and more whether Parties wish to make these wider financial dynamics visible as part of assessing implementation of the Framework.

As SBSTTA considers both the Global Review and the continued development of the monitoring framework, three priorities deserve particular attention:

• Recognise the continuing gap in assessing implementation of Target 14, including progress in aligning public and private activities and reducing financial flows associated with biodiversity loss.
• Ensure that monitoring distinguishes between finance mobilised for biodiversity and financial flows that continue to drive biodiversity loss, so that progress in one is not mistaken for progress in the other.
• Avoid allowing measures of disclosure or
  finance mobilisation to become substitutes for measuring real-world policy change, implementation and biodiversity outcomes.

Ultimately, the success of the KMGBF will not be determined simply by how much additional finance is mobilised for biodiversity. It will depend on whether Parties progressively implement Target 14 by transforming the broader policy, fiscal and financial systems that continue to drive biodiversity loss. Monitoring should help make that transformation visible.