Start of COP30: Implementation Has to Mean Accountability

Belém, Brazil – November 10, 2025

COP30 opens today with leaders promising an “implementation COP.” Brazil’s Presidency has framed it as a moment of cooperation, launching the Baku to Belém Roadmap and the Tropical Forests Forever Facility (TFFF) to mobilise more money for climate and nature.

Yet implementation without accountability will fail. As the Forests & Finance Coalition’s research shows, the global financial system still channels hundreds of billions into activities that destroy forests and violate human rights. The same governments pledging funds for forest protection continue to let their banks and investors finance deforestation with impunity.

Finance reform: rhetoric vs. rules

The Baku to Belém Roadmap is politically useful but non-binding. It reinforces a familiar pattern—treating public money as a lever to “mobilise” private capital. For developing countries already burdened by debt, this model risks deepening dependency rather than delivering justice.

FFC’s position remains clear: grant-based, public finance must be central, and financial regulation—not financial products—must drive implementation. Governments must move beyond voluntary reporting and adopt enforceable due-diligence and deforestation-free-finance laws.

The TFFF: risk of diversion

Brazil’s Tropical Forests Forever Facility has attracted over US $5.5 billion in early pledges and political fanfare. But the Facility sits outside the UNFCCC process, operating as a voluntary presidential initiative. Many see this as diverting attention and resources away from the formal negotiations where finance is meant to be decided by Parties.

Even its apparent scale is misleading. If donors treat TFFF contributions as part of their climate-finance commitments, it risks re-labelling already inadequate funds rather than adding to them. Worse, its underlying Tropical Forest Investment Fund could recycle debt instruments and speculative assets—feeding the same financial circuits that have driven deforestation.

The concept of “public-private cooperation” that underpins the TFFF mirrors decades of failed market experiments. Without binding regulation, new funds will merely recycle capital through the same destructive system.

Beyond pledges: changing the rules

It is welcome that forest protection has returned to the centre of political debate, but governments cannot drip water on the flames with one hand while pouring petrol with the other. Banks and investors based in TFFF sponsor countries remain among the world’s largest financiers of forest-risk commodities. Unless regulation changes, no new facility will stop deforestation.

That means:
• Legally prohibiting financial institutions from financing deforestation, forest degradation and rights abuses.
• Requiring central banks and regulators to integrate forest risk and biodiversity loss into supervision and monetary policy.
• Ensuring public finance is transparent, gender-responsive, and directly accessible to Indigenous Peoples and local communities.

Implementation with integrity

True implementation means changing the rules of finance and centring equity. Indigenous Peoples, women, and community leaders have protected forests for generations; their leadership and decision-making power must shape every new initiative. Gender-just, community-led finance delivers real resilience—models that governments should strengthen within, not outside, the UNFCCC framework.

What we’re watching

As negotiations unfold, FFC will be tracking:
• Finance language in the Baku to Belém outcomes and NCQG drafts.
• The governance, safeguards, and transparency of the TFFF.
• Inclusion of land, forest and finance issues within the Just Transition Work Programme (JTWP).
• Retention of MOI and gender-responsive metrics in the Global Goal on Adaptation (GGA).
• Pushes to expand flawed carbon and biodiversity markets under Article 6.

Our message

Implementation without enforceable rules will not deliver. The world cannot trade or offset its way out of ecological collapse. To truly protect forests and people, governments must stop financing destruction and start regulating finance.

Implementation must mean accountability.