Issue #78 of the Carbonaires Monthly Newsletter previews COP31 in Antalya, which runs from 9 to 20 November. COP31 is an implementation COP. No big new carbon market rules are on the table, but demand for high-integrity credits and removals is arriving from governments, compliance markets and corporate standards.
The backdrop
The run-up to COP has again brought sobering reports. UNEP’s Emissions Gap Report 2026 finds that current policies point to 2.8°C of warming this century, or 2.6°C if national climate plans (NDCs) are delivered in full (UNEP, 2026). Overshooting 1.5°C is now the working assumption. The latest NDC Synthesis Report shows new plans would put 2035 emissions only about 6% below 2019 levels, or around 9% including conditional pledges (UNFCCC, 2026a).
The politics are also harder. The United States has left the Paris Agreement and its withdrawal from the UNFCCC takes effect in February 2027. The closure of the Strait of Hormuz after military strikes in late February triggered an energy shock that has pushed energy security up the agenda.
Antalya: an implementation COP under a split presidency
COP31 runs from 9 to 20 November in Antalya under an unusual arrangement. Türkiye holds the Presidency, led by Minister of Environment, Urbanisation and Climate Change Murat Kurum, while Australia’s Chris Bowen, as President of Negotiations, leads the negotiations. The Leaders’ Summit takes place on 11 and 12 November.
With no big-ticket negotiation outcomes on the agenda, many hope that implementation can take centre stage. The issues on the table are tripling adaptation finance, operationalising the just transition mechanism agreed in Belém, the climate finance work programme and the future of the Mitigation Work Programme. The second Global Stocktake also begins, and trade, including carbon border adjustment mechanisms, is expected to cause friction. The Presidency’s own agenda features a “35 by 35” electrification pledge and its Climate Implementation Bridge, which aims to turn national climate priorities into investment-ready projects. There is no standalone carbon markets initiative, although carbon markets fall within the Finance and Trade day on 13 November.
What about carbon markets?
The Article 6 rulebook was completed in Baku and is not due for review until 2028, so negotiations concern implementation rather than new rules. Funding is the likely point of contention. The UN infrastructure behind Article 6.2, including the international registry and technical expert reviews, faces a shortfall of about US$8 to 9 million (Abatable, 2026), and Parties are divided over whether usage fees should help close it (IISD, 2026). The Supervisory Body of the Paris Agreement Crediting Mechanism (PACM) has also flagged “the critical funding shortfall for 2028 and beyond” (UNFCCC, 2026b). The PACM now has five approved methodologies and its first issuance, but its registry is not expected until early 2027 and several removal-related rules, including on the reversal risk buffer pool, carry over into next year. Countries’ second Biennial Transparency Reports, due by 31 December, should also show much of the authorised volume from 2023 and 2024 as corresponding adjustments.
A market maturing: demand is starting to arrive
The Coalition to Grow Carbon Markets, co-chaired by Kenya, Singapore and the UK, is due to publish a policy playbook at COP31 (Coalition to Grow Carbon Markets, 2026). It builds on the Shared Principles for Growing High-Integrity Use of Carbon Credits issued at COP30 and aims to stimulate demand by giving companies the confidence to buy high-integrity credits. Several members are already acting on the principles: New Zealand by recognising and endorsing high-quality credit schemes, and Canada through a recommended minimum set of eligibility guidelines for Canadian carbon removal credits. Türkiye joined the Coalition in August.
A UK-EU deal on linking emissions trading systems (ETSs) is on the table for the UK-EU summit in Brussels on 20 November, the final day of COP31. This matters for carbon dioxide removal (CDR) in two ways. On demand, both systems are moving to support durable removals, but differently: the UK intends to integrate engineered removals into the UK ETS, while the European Commission has proposed auctioning 250 million additional allowances between 2031 and 2040 to fund central purchases of an equivalent volume of permanent removals (Fastmarkets, 2026). Linking will require a decision on how these approaches fit together (Burke, Meissner and Taschini, 2026). If they are reconciled, a linked market could in time give removals a larger and more consistent demand signal. On infrastructure, EU emitters cannot currently count CO2 stored in the UK against their EU ETS obligations. The EU ETS review proposal would allow this from 2031 for a linked country, subject to a Commission decision (CCSA, 2026). This could open the way to cross-border transport and storage agreements using UK North Sea storage, although whether removals stored this way would qualify for EU purchases is not yet settled.
Sovereign buyers are also moving from pledges to tenders. Germany has launched a tender for up to 1.1 million PACM credits to cover federal government travel and events (Carbon Herald, 2026a), and Singapore is tendering for at least 12 million internationally transferred mitigation outcomes, which could include removals (CarbonCredits.com, 2026). Korea plans to use COP31 to gauge interest in a new global carbon market. As host, Türkiye is building its own: its pilot ETS runs from 2026 to 2027, with reporting only this year, and whether offsets can be used is yet to be decided (ICAP, 2026).
The removals angle
Removals are also entering corporate frameworks. The Science Based Targets initiative’s new Corporate Net-Zero Standard requires large and medium-sized companies in high-income countries to support removals equal to at least 1% of their ongoing emissions from 2035 (ESG Dive, 2026). At COP itself, a second dedicated carbon removals pavilion, run by Think Negative, and a ministerial event on carbon management with the Presidency on 19 November will give the sector more visibility.
AI and data centres
One further development is worth noting from an infrastructure perspective. The Presidency has published the text of the Antalya Artificial Intelligence Pledge, a voluntary commitment open to governments, businesses, investors and other organisations (COP31 Presidency, 2026). Citing the IEA, it notes that electricity consumption from AI-focused data centres rose by 50% in 2025. It invites signatories to increase the share of AI infrastructure powered by zero- and low-emission energy, design data centres for energy and water efficiency, support assessment and reporting of the environmental impacts of AI systems and support AI for climate action in developing countries. Signatories are invited to take stock of collective progress at each COP until 2030, starting with COP32.
The pledge does not mention carbon removals. However, the technology sector already plays an outsized role in the removals market: Microsoft accounted for 78.5% of disclosed durable CDR tonnes contracted as of April 2026 (CDR.fyi, 2026), while its reported emissions rose by about a quarter in its 2025 fiscal year, driven largely by new data centre construction (Carbon Herald, 2026b). As AI infrastructure grows, so will its residual emissions, and a framework for thinking about AI and data centres from a sustainability perspective could be an early step towards the sector becoming a larger source of demand for removals.
Download the full briefing paper
The full briefing paper goes further, with the charts and table behind this analysis, what COP31 means for corporate buyers, investors and project developers, a glossary and the full references.
Carbonaires at COP31
Carbonaires will host two sessions in the Blue Zone, and we would be delighted to see you in Antalya.
Thursday 12 November, 16:00 to 16:45, Türkiye Pavilion: “Mobilising Carbon Finance in Türkiye: From Climate Ambition to Investment-Ready Projects”. The panel will explore how carbon markets can draw climate finance into Türkiye and turn national ambition into investable projects. Moderated by Sascha Roest-Ellis, Chief Commercial Officer, Carbonaires.
Friday 13 November, 09:30 to 10:30, Think Negative CDR Pavilion (D250): “Demand in Practice: How Buyers, Banks and Governments Scale Carbon Removal”. A panel following a buyer’s journey from procurement, through the policy that shapes it, to how banks and financiers lend against an offtake, with speakers from Lower Thames Crossing, Centalion and UBS, moderated by Marika Niekowal, Policy Manager, Carbonaires.
Carbonaires is a proud sponsor of the Think Negative CDR Pavilion.
Meet us at COP31
Mobilising Carbon Finance in Türkiye. Thursday 12 November, 16:00 to 16:45, Türkiye Pavilion.
Register for the Türkiye panelDemand in Practice. Friday 13 November, 09:30 to 10:30, Think Negative CDR Pavilion (D250).
Register for Demand in Practice



