From COP27 to JET-IP: South Africa's climate finance reality in 2026

South African climate finance is now regulated finance, anchored by the Climate Change Act 2024, the JET-IP investment plan and ISSB-aligned disclosure expectations channelled through the JSE.

Three instruments now anchor the regulated environment — the Climate Change Act 2024, the Just Energy Transition Investment Plan (JET-IP) and ISSB-aligned disclosure expectations channelled through the JSE Sustainability Disclosure Guidance.

This piece addresses jetip, africas, reality as the core focus, drawing on Kettle's South African public-sector and corporate advisory practice.

At COP27 in Sharm El-Sheikh in November 2022, the headline announcement for South Africa was the elaboration of the Just Energy Transition Partnership initially signed at COP26 — an USD 8.5 billion finance package from the International Partners Group of the United States, the United Kingdom, the European Union, France and Germany. Four years on, the package has been augmented, the political economy has shifted, and the binding instruments inside South Africa have caught up with the international rhetoric.

This advisory note sets out what the JET-IP architecture actually finances in 2026, what the Climate Change Act 2024 requires of JSE-listed boards, where ISSB IFRS S1 and S2 fit into the JSE disclosure regime, and what concessional finance is genuinely accessible to the entities that need it.

What COP27 actually delivered for South Africa

Three concrete outcomes from COP27 that matter four years on.

• The Just Energy Transition Investment Plan 2023-2027 was launched at COP27, setting out approximately R1.5 trillion of investment requirement across electricity, new energy vehicles and green hydrogen.
• The International Partners Group (IPG) financing package was expanded by additional pledges from the Netherlands, Denmark and Switzerland, taking the headline figure above USD 11.6 billion.
• The Loss and Damage Fund was agreed in principle at COP27 and operationalised at COP28; South Africa engages with it as a recipient-eligible economy in transition.

The headline figures matter less than the underlying instrument design. The IPG package is a blend of grants, concessional loans, commercial loans, guarantees and technical assistance. Less than 4% of the announced amount is in pure grant form. Approximately 60% is commercial-rate debt. The advisory work for South African counterparts is unpacking which tranches are genuinely concessional and which are commercial finance with a climate label.

The Climate Change Act 2024 in practice

The Climate Change Act, assented in 2024, is the binding domestic instrument that translates the Nationally Determined Contribution into operational obligations. Five elements of the Act matter for JSE-listed boards.

1. Sectoral emission targets — the Minister of Forestry, Fisheries and the Environment sets binding emission targets by economic sector, with allocated reduction obligations.
2. Carbon budgets — large emitters are allocated multi-year carbon budgets, with a regulated overage and pricing mechanism.
3. Provincial and municipal climate plans — provinces and metros are required to prepare adaptation and mitigation plans that listed entities operating in those jurisdictions need to align with.
4. The Presidential Climate Commission is given a statutory role as an advisory body, with formalised public consultation requirements.
5. Reporting obligations — covered entities report to the Department of Forestry, Fisheries and the Environment (DFFE) on a defined cadence, with civil penalties for non-compliance.

ISSB IFRS S1 and S2 — where they sit in SA disclosure

The IFRS Foundation issued the inaugural ISSB sustainability and climate standards — IFRS S1 (general requirements for sustainability-related financial information) and IFRS S2 (climate-related disclosures) — in 2023. The JSE Sustainability Disclosure Guidance, issued by the JSE in 2022 and updated since, anchors listed-entity climate disclosure expectations to the ISSB standards on a phased basis.

What this means in practice for a JSE-listed CFO in 2026: climate-related disclosures are no longer the voluntary additional reporting they were a decade ago. They are integrated into the annual financial reporting cycle, subject to audit committee oversight, and increasingly subject to limited assurance under ISA standards.

Where the concessional finance actually is

The JET-IP architecture is the largest concessional finance pool addressed at South African energy transition. The plan identifies three priority sectors and assigns financing instruments to each.

_Source: Just Energy Transition Investment Plan 2023-2027 and IPG implementation reports. Rand values approximate as published._

Sector · JET-IP investment requirement (Rbn) · Dominant instrument type · Concessionality available

• Sector: Electricity (transmission, generation, just transition) — JET-IP investment requirement (Rbn): 1030 — Dominant instrument type: Concessional debt; guarantees — Concessionality available: Material — sovereign-backed
• Sector: New energy vehicles — JET-IP investment requirement (Rbn): 128 — Dominant instrument type: Commercial debt; DFI co-investment — Concessionality available: Limited
• Sector: Green hydrogen — JET-IP investment requirement (Rbn): 319 — Dominant instrument type: Project finance; offtake-backed — Concessionality available: Variable — depends on offtake
• Sector: Municipal / just transition supplementary — JET-IP investment requirement (Rbn): Additional allocation — Dominant instrument type: Grants; technical assistance — Concessionality available: High but capacity-constrained

The genuinely concessional finance sits in three places. First, multilateral concessional facilities — Climate Investment Funds, Green Climate Fund, IBRD and AfDB concessional windows — accessed primarily by Eskom and the DFIs. Second, the supplementary IPG grants for just transition support — used for community impact, reskilling and small-scale municipal projects. Third, the technical assistance line — which underwrites pre-feasibility work for projects that would not otherwise get to bankability.

The Carbon Tax Act and the regulatory perimeter

The Carbon Tax Act 15 of 2019 entered Phase 2 with progressive rate increases and a narrower allowance regime. The rate path published by National Treasury in successive Budget Reviews has the headline rate rising materially through 2030. The interaction between the carbon tax and the carbon budgets allocated under the Climate Change Act is now the single most material climate-related cost line for energy-intensive listed entities. Scenario modelling under three carbon-price paths is the minimum disclosure expectation under IFRS S2.

Climate finance for South Africa in 2026 is regulated finance. The boards that treat it as voluntary disclosure are operating against the wrong instrument.

— Kettle Consulting climate advisory

What this means for JSE-listed boards in 2026

Four practical priorities for the audit committee and the social and ethics committee.

1. Adopt IFRS S2 climate-related disclosures on the phased basis the JSE Sustainability Disclosure Guidance anticipates. Run the scenarios that the standard requires, not generic narrative.
2. Engage the carbon budget allocation process under the Climate Change Act early. The bigger the emitter, the more material the allocation outcome.
3. Identify which projects in the company's capital plan are JET-IP eligible, and engage the IPG-supporting facilities — Climate Investment Funds, Green Climate Fund — through the appropriate intermediary.
4. Build the carbon tax cost line into the rolling forecast under three rate paths. The cost is no longer marginal for energy-intensive sectors.

Practical implications for 2026 reporting

The integrated report for the 2026 financial year should reflect three things that were optional in 2022: explicit ISSB IFRS S1 and S2 alignment with phased compliance disclosure, scenario analysis under at least three carbon-price paths, and a stated position on the company's carbon budget allocation under the Climate Change Act. The audit committee charter should reference the Presidential Climate Commission's public outputs as part of the external environment review.