Published: 23 June 2025. Written by: Tuula Honkonen
Despite the EU’s strong rhetorical commitment to transparency and public participation, civil society is often left on the sidelines when the Union prepares its positions for international climate negotiations. As seen in COP-29 in Baku, early-stage engagement is essential—not just for legitimacy, but for better outcomes.
A Participatory Ideal Facing Strategic Realities
Civil society participation in climate policy-making is a subject that easily gives rise to debates. It is a goal that most policymakers openly support, but the reality may end up looking quite different when the multilateral negotiations get serious. One needs to just look back at the experiences at COP-29 in Baku in late 2024 to see how civil society participation was repressed in many ways. At the same time, there is increasing pressure to reduce the size of these annual “climate expos”. These developments highlight the need to more effectively engage stakeholders at the earlier stages of global climate policymaking, namely during the preparation of the state and country group positions.
As was noted in a previous blog post, preparation of the EU position for international climate negotiations is not particularly transparent or open to civil society participation. This is the case despite the EU’s strong commitment to transparent and participatory governance. Indeed, the situation could be said to reflect a broader secrecy paradigm in EU policy- and law-making. Nevertheless, it is also understandable why the EU upholds certain secrecy in its preparation for climate negotiations: international negotiations are based on confidentiality and strategic action, which justifies keeping the relevant domestic preparatory process largely beyond public scrutiny. Furthermore, it is to be noted that the EU has, in Article 4 of Regulation 1049/2001 on Access to Documents, a legally valid basis for preventing public access to preparatory documents if publicity would undermine the interests of the EU in international relations.
The secrecy paradigm reflects the trade-off between increased transparency and participation on the one hand, and the effectiveness of the EU as a negotiator on the other. Preparing the negotiation position and working out agreements are easier when there is a smaller audience to whom they need to be explained and from whom legitimacy has to be sought. However, civil society participation may well increase the negotiation effectiveness of the EU. This may be achieved by enhancing the relevant knowledge base and assisting in finding compromises among the Member States, or even between the EU and the other parties in the negotiations.
No Formal Role for Civil Society
Despite the prevailing art of balancing between necessary confidentiality and excessive secrecy by the EU, civil society actors do have a number of ways and routes to participate – or at least bring their views known to the EU officials and institutions that play a role in the preparation of the Union’s position to international climate negotiations. This participation is largely based on ad hoc and bottom-up arrangements. There is no official dedicated mechanism for participation or presenting comments on the draft EU negotiation position. Consequently, civil society actors have to rely on occasional, invitation-based expert presentations in preparatory meetings or engagement in informal communication with Member States and Commission officials – but not with the Council which is the principal preparer and decision-maker with regard to the EU position, and notorious for lack of operational transparency and participation.
In theory, a formal civil society consultation mechanism could be added to the EU preparatory process for the UN climate negotiations. The public consultations for citizens and stakeholders that the Commission routinely organizes as a mechanism for the civil society to contribute to the EU policy- and law-making processes could be used as a model. In practice, however, as also argued by the Commission in the research interviews, the idea is not realistic: it would add another layer to the preparatory process, which already takes a considerable amount of time and resources. Moreover, the EU institutions do not see any clear failing or deficiency in the current process. Thus, a formal mechanism for engaging civil society in the EU preparatory process is not likely to be introduced.
How Civil Society Can Engage More Effectively
Given the limited possibilities to engage in the EU preparatory process for climate negotiations, it would be wise for civil society actors to invest in improving the quality of their existing participation. From the EU perspective, increasing civil society participation involves a heightened administrative burden, and so increasing the effectiveness of the participation would be in their interest as well. In short: public participation should be such that it is worthwhile for both sides. Based on research, the following advice could be discerned to improve the quality of civil society participation in the EU preparation of its position for international climate negotiations:
- Make sure that you reach out to the right people in the EU institutions. It is crucial to know and understand the preparatory process, the roles of different institutions and actors at each stage and how your messages could reach through.
- Bring new perspectives to the discussions that take issues forward. Try to be realistic and constructive in your comments. This is what the EU institutions and actors appreciate and say that is currently often lacking in their communication with civil society organizations regarding the EU’s international climate policymaking.
- Try to find common ground with the policymakers. Avoid one-sidedly strategic or politically colored arguments or talk that is more akin to campaign slogans. All these qualities diminish the practical value of your participation.
- Remember discretion. Be aware of the sensitivities of the negotiations and leave the most radical activist mentality at home. Mutual respect is important, alongside an understanding of each party’s fundamental rationale in the preparatory and negotiation processes.
- Bring your expertise to the discussions and the whole preparatory process. Policymakers increasingly expect to benefit from the special knowledge and expertise that civil society actors bring to the processes. Even dressing up your participation as an effort to benefit the EU policy making process by bringing special knowledge to it could be worthwhile to avoid the risk of being ignored.
- Use your networks and umbrella organizations. They provide important information and contacts, sometimes even direct access to relevant policymakers.
- Explore the possibility of participating through the European Economic and Social Committee (EESC). It has become increasingly interested in EU-wide participation in international climate negotiations and its role could well strengthen in the future.
- Remember that policymakers’ negative experiences in the engagement with civil society have lasting repercussions while positive ones may open new doors in the future.
Constructive Engagement Opens Doors
Until the EU revisits its internal processes, civil society must work within existing structures to make its voice heard in the preparation for international climate negotiations. While the lack of formal mechanisms can be frustrating, constructive and strategic engagement can still make a difference. Policymakers remember both negative and positive interactions. Investing in meaningful, respectful, and knowledge-based dialogue today may well lead to greater influence tomorrow.
This blog post is based on a recently published article: Tuula Honkonen: Civil society participation in EU preparation for UN climate negotiations − questions of openness and transparency Review of European, Comparative & International Environmental Law (RECIEL) (2025) (open access)