Delivering on Paris Agreement commitments requires action at every level of government and throughout society. At the subnational level, provinces, states and municipalities, and the private sector, are increasingly expected to develop their own climate response plans that are aligned with national goals. However, the necessary technical capacity, data systems and institutional frameworks to assess greenhouse gas profiles, set meaningful targets, understand the impact of policies and actions, and report progress transparently are often lacking.

This gap highlights a key challenge: how can countries properly account for subnational actions’ collective contribution to national mitigation targets? And how can they ensure consistency and avoid double-counting when aggregating impacts across multiple jurisdictions?

In Argentina and South Africa, ICAT has provided support to address this challenge through approaches tailored to the unique situations of each country. Both have national laws mandating subnational climate action, yet some regions lack sufficient local capacity to deliver. Their experiences offer practical lessons for other countries facing similar challenges.

Argentina: Strengthening provincial climate plans

Argentina’s national climate change law (Law 27,520) requires all provinces to prepare Climate Change Response Plans that are aligned with the country’s NDC targets. However, a significant capacity gap existed between national requirements and what provinces could realistically deliver. There was also a need for a systematic way to assess the extent to which provincial plans collectively supported national targets, and how to identify overlaps and gaps across jurisdictions.

The second ICAT project in Argentina focused on systematizing provincial plans and applying practical tools to evaluate their aggregate impact. This involved a thorough analysis of available provincial Climate Change Response Plans and evaluating them against the National Plan for Adaptation and Mitigation to Climate Change. The aim was to understand the level of policy development at national and subnational levels, and to assess how existing actions contributed to national objectives.

ICAT’s Climate Action Aggregation Tool (CAAT), alongside the ICAT Non-State and Subnational Action Guide, was essential to this project. The tool allowed the project team to identify, quantify and aggregate the impact of subnational actions, while identifying compatibility between provincial and national measures and avoiding double-counting. 

The project successfully collated data from provincial plans into a systematic, accessible format. This established a robust methodology for consistently collecting and organizing information. Pre-validated CAAT analyses were completed for nine provinces, introducing 30 mitigation measures from provincial actors (14 in the energy sector and 16 in LULUCF). 

The work also identified common areas for improvement in provincial plans, such as addressing incomplete descriptions, weak sectoral linkages and gaps in progress indicators and financing information. These findings help to indicate where strengthened future plans and targeting capacity building are most needed.

The project also significantly enhanced transparency by updating Argentina’s National Climate Change Information System (SNICC). Working with a local company, the platform was modernized to host the latest greenhouse gas inventory results from Argentina’s first BTR and fifth Biennial Update Report, both submitted to the UNFCCC in 2024. The updated platform now provides accessible emission factors, inventory time series and monitoring indicators, making critical climate information available to a broader audience.

South Africa: Building subnational capacity 

South Africa’s Climate Change Act (Act No. 22 of 2024) requires provinces and municipalities to set and report emission reduction targets that are aligned with national objectives. Although the Act stated that local governments must develop Climate Change Response Plans within one year, widespread capacity constraints placed this target out of reach for many jurisdictions.

In South Africa, ICAT supported the Department of Forestry, Fisheries and the Environment in operationalizing the requirement of the Climate Change Act by developing a bottom-up monitoring system and building provincial capacity for greenhouse gas inventories and mitigation MRV. The targeted approach combined technical training, MRV framework development and direct hands-on support for local climate response planning.

As part of the project, ICAT provided direct assistance to Nkangala District Municipality, which has a population of around 1.6 million people across six local municipalities. This work served as a model for how other provinces and districts might build their institutional capacity to comply with the new legislation.

In Nkangala, the project supported the development of a first-generation greenhouse gas inventory using the Let’s Respond Toolkit and IPCC 2006 guidelines. The inventory compiled emissions data across the Energy, Industrial Processes and Product Use (IPPU), Agriculture and Waste sectors, from sources including the South African Greenhouse Gas Emissions Reporting System and agricultural census data. Due to data limitations, the inventory provides an indication of sectoral contributions rather than accurate estimations. However, it does establish a baseline that can be refined as more comprehensive data becomes available over time.

Building on the inventory, the project helped Nkangala to develop a comprehensive Climate Change Mitigation Response Strategy. This included establishing implementation structures with clearly defined roles and responsibilities, setting action plans with timelines and risk management provisions, developing financial strategies, identifying funding sources and requirements, and identifying capacity building needs for local government staff. 

Finally, the project supplied comprehensive training materials and workshops to improve provincial capacity for greenhouse gas inventories, quality assurance and quality control procedures, target-setting and MRV. It created peer-learning opportunities among provinces and strengthened institutional coordination across government levels.

Subnational action to meet national targets

Argentina and South Africa share common requirements for effective aggregation of subnational climate action. For example, standardized reporting templates can ensure consistency across jurisdictions, while training on national guidelines helps provinces and municipalities to understand what is expected of them. Dedicated local climate staff are needed to sustain implementation over time.

Data gaps and challenges persist, but both countries will continue to work on climate response planning, action and reporting at the subnational level. Argentina plans to integrate CAAT into the revision process for provincial Climate Change Response Plans and continue to improve the SNICC platform’s accessibility and data coverage, while South Africa aims to expand the Nkangala model to other provinces and districts.

By developing practical methodologies and building provincial capacity, ICAT has helped both countries to make progress in aggregating and transparently reporting subnational climate action. This success demonstrates how national commitments can effectively integrate action at the subnational level, and how the collective efforts of provinces and municipalities can make a real contribution to achieving national climate targets.