Intermediaries and complexity: assessing emissions-based governance in the European Union’s EU-ETS

Scientists have specified that, by the year 2030, aggregate global greenhouse gas (GHG) emissions must be halved to have at least a 67% chance of meeting the Paris Agreement. A key challenge is the governance of GHGs. This article investigates the evolution of the EU’s Emissions Trading System using the Regulatory–Intermediary–Target (RIT) framework. Specifically, we outline the role of “emissions governance” intermediaries to monitor, report, and verify (MRV) emissions reductions. This comes with both pros and cons. First, there are a multitude of public and private actors, rules and regulations, that exist within this system. Yet, as the RIT framework makes clear, this can lead to opportunities for capture of regulatory targets and regulators. On the other hand, given that public institutions and governance actors have yet to succeed in significantly driving down emissions, non-state and private actors are increasingly being relied on to plug climate governance gaps—especially as intermediaries with important MRV responsibilities. The application of the RIT and findings have important implications for climate governance scholarship and related climate governance mechanisms.