COP Talks: Formal Delegations, Informal Access

By banning fossil fuel linked interests from its list at the annual UN climate conference – Conference of the Parties (COP), the European Commission has cleaned up its own delegation. At the past two summits, held in Baku, Azerbaijan, in 2024, and in Belém, Brazil, in 2025, Brussels has issued conference passes only to people representing EU institutions, screening out anyone campaign groups have flagged as representing a polluting industry. It is a real change, following years of civil society groups pushing the Commission and Member States to stop giving industry-linked advisers seats inside official delegations.

The logic behind that shift is straightforward: a delegation negotiating the EU’s climate position should not give access, even informal or secondary access, to people whose employers stand to benefit from international climate policies that lack ambition or pursue business models that conflict with the overarching goals of the UN Framework Convention on Climate Change (UNFCCC). Keeping industry-linked participation out of delegations is meant to protect the integrity of that process, not just its optics.

But the Commission only controls one door. National governments control the rest, and our analysis of the Member State delegations at COP30 in Belém shows that several of them still accredit individuals linked to fossil fuels. A handful of capitals continue to wave through people linked to fossil fuel companies and industry associations, attaching them to the same delegations that negotiate the EU’s climate position on the international stage.

Their presence at COP doesn’t prove they swung a vote. But it does put them inside a forum where international climate policy positions and broader climate solutions are shaped, raising a key question: who gets to walk in the door, and on whose authority?

Most non-state participants who make it into the EU Member State delegations do so via what is known as a Party Overflow badge.

Overflow badges are issued by Parties to the UNFCCC, the 197 countries and the EU that are members of the Convention, to additional participants affiliated with a national delegation who are not part of its formal negotiating team: typically, representatives of various state institutions, researchers and experts, youth activists or invited guests from business or civil society.

Overflow delegates cannot negotiate or speak on a country’s behalf. But the badge gets them into the COP Blue Zone: negotiation spaces, side events, exhibition halls. Most importantly, it may grant them privileged access to national decision-makers and, at times, even to briefings and intelligence sharing, according to some negotiators we interviewed last year for our research. And all without the disclosure requirements observers face under UNFCCC accreditation. The Overflow badge shows a Party affiliation, not who’s paying a delegate’s way. On paper, a fossil fuel executive at COP can look indistinguishable from a government adviser.

This matters because of scale: at COP30, more than 95% of non-state actors who entered through EU Member State delegations did so on Party Overflow badges rather than Party badges. The core Party delegations, which include the negotiators who formally hold the pen during negotiations, remain overwhelmingly government officials. So, if there’s a question to ask about private-interest access, this is where to ask it.

Strip out the government officials, and a clearer picture of who is gaining access to COP through official Member State delegations emerges. Of the 885 non-state representatives Transparency International identified across the EU and Member State delegations, 526 represented business and commercial interests, against 359 from civil society, youth, academic and other organisations. Excluding media, support personnel, as well as delegates whose affiliations could not be identified, business representatives accounted for almost 60% of all non-state delegates. For every two representatives from civil society and other non-state groups, there were roughly three from business.

While business representatives are not a homogeneous group and do not all have fossil fuel ties, their disproportionate presence relative to other non-state participants raises broader questions about the balance of interests represented in climate negotiations.

That balance was not consistent across the bloc. Slovenia, Czechia and Germany reserved their Party and Party Overflow badges almost exclusively for government and public-sector representatives. Sweden, France and Portugal, by contrast, opened their delegations far more widely to outside actors. Looking at Party and Party Overflow delegates combined, France fielded the largest EU non-state contingent at COP30, with 268 delegates, while Sweden had the highest proportion of business representatives: nearly 70% of its delegation, against roughly 50% in France and Portugal.

Within that business contingent, a distinct subset carries a direct fossil fuel link. Fossil fuel-linked representation was not widespread across EU delegations, but where it existed, it was concentrated. Transparency International identified 63 delegates with links to fossil fuel interests across nine Member States: more than 7% of all non-state delegates accredited through the delegations examined.

Four countries (France, Portugal, Sweden and Italy) accounted for 52 of the 63 identified delegates, or 83% of the total. France alone accredited 26, more than a third of the total 63. Overall, more than four in five fossil fuel-linked delegates were senior leaders, including top executives and board members, meaning representation came overwhelmingly from individuals in decision-making authority.

The nature of that fossil fuel link varied by country. Portugal’s fossil fuel-linked representation was concentrated among energy companies. France’s was more mixed, combining energy firms with financial institutions carrying exposure to the fossil fuel economy, a reminder that “fossil fuel-linked” reaches well beyond the household names of oil and gas.

Identifying who enters a COP through a national delegation only tells part of the story. The next question is what interests they represent once they arrive. To explore that, Transparency International examined the public lobbying records of fossil fuel-linked companies and organisations represented in EU Member State delegations, using data by LobbyMap, an independent tracker of corporate climate lobbying, where available. Their records offer a window into the policy debates these organisations are engaged in across Europe and, by extension, the priorities they may bring with them into the wider climate-policy conversation.

The first finding is that the debate is rarely between climate supporters and climate sceptics. Most fossil fuel-linked entities represented in the Member State delegations publicly support the Paris Agreement and acknowledge the need for climate action. Across the companies assessed, LobbyMap found that they actively engage with policymakers on climate and energy policy, ranging from renewable energy and energy efficiency to emissions trading, hydrogen and sustainable finance.

Yet public support for climate goals does not always translate into support for policy pathways that are aligned with the objectives of the Paris Agreement.

The fossil fuel-linked entities identified in EU Member State delegations was far from uniform. Several companies whose operations retain some exposure to fossil fuels nevertheless appear, on balance, supportive of ambitious climate policy. According to LobbyMap assessments, companies such as EDP and Enel generally back EU measures aimed at accelerating the transition away from fossil fuels and strengthening climate regulation.

EDP stands out in particular. Ahead of COP28, the company joined calls for a global commitment to triple renewable-energy capacity by 2030 and has publicly supported stronger energy-efficiency measures for industry. LobbyMap consequently classifies its overall climate-policy engagement as broadly aligned with the objectives of the Paris Agreement.

At the same time, company positions do not always match those of the trade associations that represent them. A number of companies assessed as broadly supportive of climate action, such as Edison, are also members of industry groups whose lobbying positions are less aligned with ambitious climate targets. The result is a reminder that influence rarely runs through a single channel. What a company says directly and what it supports indirectly can differ substantially.

Whether to accelerate away from fossil fuels or preserve flexibility for continued fossil fuel use remains one of the most contested questions in the UNFCCC process. If there is one policy position that repeatedly appears across Tier 1 and Tier 2 fossil fuel-linked entities represented in EU Member State delegations, it is support for a continued role for fossil gas in the energy transition.

LobbyMap assessments show that companies such as ENGIE, Fluxys, TotalEnergies, E.ON and Siemens Energy have supported policies that would preserve or expand the role of gas within Europe’s future energy system. These positions include support for gas infrastructure, liquefied natural gas facilities, gas-fired power generation and certain hydrogen pathways linked to fossil fuels.

The argument is usually framed in terms of energy security and the need for a transitional fuel while renewable capacity scales up. Critics, however, note that these positions sit uneasily alongside scientific assessments indicating that pathways compatible with limiting warming to 1.5°C leave little room for long-term expansion of fossil gas production or infrastructure.

Some companies also appear more sceptical than governments about the achievability of the Paris Agreement’s most ambitious temperature goal. According to LobbyMap, both TotalEnergies and Siemens Energy have questioned whether limiting warming to 1.5°C remains realistic. While exceeding 1.5°C is now considered unavoidable according to the new UNEP report, that objective still continues to serve as the central benchmark for international climate policy and was reaffirmed by the Mutirão Decision at the COP30 in November 2025.

When it comes to the financial sector, the question they seem to be engaged in is whether climate-related financial regulations should exist and how far they should go. These debates are not formally part of the COP negotiations. Yet they can take a central stage in side discussions taking place across the Blue Zone, where governments, financial institutions and other stakeholders’ network and debate climate solutions beyond international policy.

Most banks, insurers and asset managers represented within EU delegations generally support sustainable-finance frameworks and climate-related disclosure requirements for companies. LobbyMap assessments of institutions including AXA, BNP Paribas and Crédit Agricole show broad support for such regulations. BNP Paribas and Crédit Agricole have even reduced their fossil fuel financing compared with the previous year, suggesting a degree of movement away from fossil fuel investment.

At the same time, LobbyMap assessments show that these institutions have advocated simpler reporting requirements and greater flexibility in the EU rules that classify which investments count as green. Critics, however, see a risk that simplifying disclosure obligations could weaken transparency and make progress harder to measure.

JPMorgan presents a different profile. The world’s largest fossil fuel financier, providing US$58.2 billion in fossil fuel financing in 2025, was represented in the French delegation at COP30. According to LobbyMap, the bank supports climate action in principle but has taken more sceptical positions on elements of sustainable-finance regulation. LobbyMap records show reservations regarding mandatory climate disclosures and a more limited role for green-investment classification systems in directing transition finance. The bank has also continued to support an ongoing role for fossil fuels in the global energy mix.

The European Commission has shown that tightening the front door is possible – it has screened its own accredited delegates and kept identified fossil fuel representatives out. The side door run through national capitals shows that a Brussels-only fix leaves most of the building unguarded.

Closing this gap doesn’t require reinventing the accreditation system. It requires:

• Extending screening to Member State delegations. EU Member States should adopt the same approach that the European Commission has applied to accrediting its own delegation in the last two COPs. The Commission should also commit to maintaining and strengthening this practice at COP31 in Antalya, Türkiye, and in future years.
• Disclosure of affiliation on the badge itself, so that a delegate’s employer – and any fossil fuel ties – are visible to other participants and the public, not just to the government that nominated them. The UNFCCC Secretariat should introduce and maintain this transparency requirement.
• Full transparency about how delegations are constituted and who is invited, including delegates’ affiliations and any paid and unpaid roles, consultancy work, or advisory positions for high-emitting industries. Member States could adopt the Integrity Pledge developed by Transparency International to strengthen the credibility of national delegations, prevent conflicts of interest, and safeguard the legitimacy and effectiveness of negotiations.
• Champion integrity reforms within the UN climate process. The European Commission and EU Member States should drive and contribute to discussions on conflicts of interest, transparency, and undue influence in UNFCCC processes. They should encourage the COP31 Presidency to promote stronger integrity standards and prioritise measures that safeguard the credibility and effectiveness of climate negotiations.

As COP31 approaches, EU Member States should match the EU’s climate leadership ambitions with stronger safeguards against corporate greenwashing and more robust oversight of business participation in UN climate negotiations.