Climate money after Antalya: who can audit our price tag
Kubatbek Rakhimov, PhD in Economics, associate professor, head of the "International Politics" educational program at the Higher School of Diplomacy and Law of the KRSU Social and Humanitarian Institute, executive director of the Applikata Center for Strategic Solutions, co-chair of the Kyrgyz-Kazakh Business Council.
On November 12, the COP31 leaders' summit concluded in Antalya. Negotiations will continue until November 20, but the main statements have already been made. They clearly show what each Central Asian country brought with it in search of climate money.
Head of the Cabinet of Ministers Adylbek Kasymaliev, in his national statement, asked to simplify access to climate financing for mountainous countries. He proposed establishing a Global Mountain Regions Resilience Center and reminded about the Issyk-Kul trust fund with Kyrgyzstan's initial contribution of $10 million. The Ministry of Agriculture proposed the international program "Organic Territories of Mountainous Countries" for 2027–2032. Minister of Natural Resources Akyl Toktobaev spoke at the regional ministerial meeting about investment opportunities under our new climate plan, NDC 3.0: clean energy, agriculture, forests and pastures, early warning systems, and biodiversity. Project names and amounts were absent from reports about this meeting.
Real money was present as well. Kyrgyzstan entered the top five countries of the Climate Investment Funds' ARISE program and will receive $30 million in concessional financing for water and agricultural resilience. In Antalya, the CLiCA regional program for Kyrgyzstan, Tajikistan, and Uzbekistan worth $296 million was officially launched. The Green Climate Fund grant within it amounts to $134 million, with roughly the same share coming from loans. Work will begin in 2027.
Our neighbors brought different proposals.
- Kazakhstan presented a national Climate Investment Platform created jointly with the Green Climate Fund. Its task is to gather a portfolio of projects ready for financing.
- On the opening day of the conference, the President of Uzbekistan was presented with 133 water, flood, and drought forecasting projects worth $3.3 billion. He instructed to draft a monthly plan for 2027. From the rostrum, Shavkat Mirziyoyev proposed a regional climate integration model with shared risk data and new financing instruments.
- Even before the summit, Tajikistan named the price tag of its NDC 3.0: 166 measures totaling $20–22.5 billion.
We also have a portfolio. In June, the Cabinet of Ministers approved the Climate Investment Program for 2026–2030: 26 priority projects, with a portfolio exceeding $465 million. In September, the draft National Adaptation Plan until 2035 was submitted for public discussion: 676 measures worth 74.5 billion som, which is about $850 million. The trouble lies elsewhere. These figures do not add up to the main one.
Kyrgyzstan presented NDC 3.0 in the autumn of 2025. The funding requirement for emission reductions and adaptation for 2026–2035 is estimated in it at $23 billion. This exceeds Tajikistan's estimate and is approximately 1.3 times our entire 2024 GDP. About $13.7 billion has already been accounted for: the budget, the private sector, donors, and state investment projects. The missing $9.3 billion remains to be found. Even if we add up the published programs with their price tags, we get about $1.3 billion. How $23 billion is formed from them and the remaining measures is not visible from the outside.
There is a detail that alarmed me a year ago. On September 19, 2025, when the document was approved, the Ministry of Natural Resources stated the demand was $12–15 billion. In the text submitted to the UN and dated September 30, the figure is already $23 billion. I never found an explanation for this discrepancy in open sources.
Therefore, the amount itself concerns me less than another question: who can audit these figures.
First, regarding what stands behind the commitments. Kazakhstan and Tajikistan calculate emission reductions from 1990, when Soviet industry was operating at full capacity. Uzbekistan calculates emissions per unit of GDP. We calculate from our own forecast. According to it, our net emissions should grow from 9.1 million tons in 2023 to 24 million tons in 2035. The promised 16% reduction from this figure means that by 2035 emissions could grow 2.2 times compared to the current level.
I do not consider this a trick. We have indeed halved our net emissions compared to 1990 and have the right to development. Our officials have stated this more than once. I agree with this logic. But then the document must serve our negotiating position, and its figures must withstand verification.
Now regarding who can verify them. The list of measures has been published. However, NDC itself refers the cost calculation of each measure to a detailed implementation plan prepared as an internal document. In the previous cycle, a draft of such a plan with the cost of each measure was submitted for public discussion; this time, it was not. National experts participated in consultations, and the Academy of Sciences was part of the working group. Individual pieces of the budget are published, but there is no general summary. Therefore, neither an independent economist, nor a university, nor an analytical center can verify today how the $23 billion was formed.
History is repeating itself right now. This week, a draft resolution on revising the plan to achieve carbon neutrality by 2050 was submitted for public discussion. It contains no total cost. It only states that no additional funds from the republican budget will be required, and measures will be financed from agency budgets and off-budget sources. This is another plan whose price tag cannot be calculated from the outside.
Why this matters is evident from the experience of the previous cycle. 92% of the achieved reductions were delivered by measures planned through internal resources. Measures relying on international support accounted for 8%. Over 2017–2024, the country attracted about $1.3 billion in international climate support, with grants making up approximately 42%. The outcomes of Antalya do not change this scale. Even together with our share of CLiCA, new money is measured at best in hundreds of millions, while the $9.3 billion gap needs to be closed over ten years.
Another detail surprised me. Kambar-Ata HPP-1, our largest project, is recorded in the NDC with zero contribution to emission reductions for both 2030 and 2035: its commissioning is scheduled for 2040 in the table of measures. A project around which the entire energy policy is built adds nothing to the figures by which we will be evaluated in this cycle.
Therefore, in my view, climate financing needs to be managed constantly, rather than once a year ahead of the next summit. I have three arguments.
Whoever owns the figures owns the negotiations. The baseline forecast and budget determine how much we can ask for and what we can be reproached with. If they cannot be verified domestically, it will be easy to dispute us externally. The question of why $12–15 billion turned into $23 billion in eleven days will sooner or later be asked by donors as well.
The region is beginning to assemble into a common framework. Uzbekistan is proposing a climate integration model, and Kazakhstan is building its investment platform. The glaciers of the Pamirs and Tien Shan form a single system, and funds distribute money based on country applications. If we lack a verifiable budget and our own expert position, we will enter the common framework bearing only requests.
And finally, the most profitable instruments are not born within a single agency. In July, the President signed the law "On Climate Activity". Most of its provisions will enter into force on January 1, 2027, including the national carbon units trading system. We have already experienced debt-for-green-projects swaps: Germany and Turkey did so. In September in Istanbul, Kyrgyzstan again proposed such swaps. In 2025, I wrote a policy note on the debt-for-climate mechanism in cooperation with Russia. The next step is to pay off part of our liabilities not with money for green projects, but with carbon units under Article 6 of the Paris Agreement. This logic can also work with China, our largest creditor. The first step has already been taken. In June, the World Bank approved the iFIRST project worth $35–50 million, the country's first carbon transaction under the Paris Agreement. The law provides a registry for such transactions. However, such schemes require joint work by the Ministry of Finance, the Ministry of Foreign Affairs, environmentalists, economists, and lawyers. A single official cannot assemble such a transaction alone.
What can be done right now, I see in four steps.
- Publish the cost calculations for NDC measures and the carbon neutrality plan, as was done in the previous cycle.
- Establish an independent expert council under the Climate Finance Center, which is already operating under the Cabinet of Ministers, with the participation of the National Academy of Sciences, universities, and analytical centers.
- The Climate Investment Program already promises a national monitoring and reporting system for climate investments. Its reports should be made public: showing once a year how much we requested and how much we actually received, starting with ARISE and CLiCA.
- Before the next climate summit, bring together experts from the five Central Asian countries so that the region arrives with a coordinated position at least on glaciers and water. The Uzbek proposal provides a ready-made framework for this.
There are a month and a half left before the climate law enters into force. The next NDC must be presented in 2030. If the budget still cannot be verified domestically by then, we will once again have to defend figures in negotiations that we cannot vouch for ourselves.
