Strategic transparency under authoritarian environmentalism: information disclosure and the role of environmental NGOs in China's national emission trading scheme

Transparency in carbon markets is considered critical to ensure market effectiveness and public accountability. Low levels of transparency and lack of participation of non-governmental actors are persistent criticisms of Chinese (pilot) emission trading systems. Building on debates around authoritarian environmentalism and China's role therein, this article analyses transparency, manifested as information disclosure, in China's national carbon emission trading scheme (C-ETS) - the largest carbon emission market worldwide. Using expert interviews and content analysis, the article outlines practices of C-ETS information disclosure and discusses its characteristics in the context of China's environmental governance. Key findings include discrepancies both between central and provincial governments related to information disclosure, and between different provincial governments. And while most industry actors lack interest and capacity to engage in C-ETS disclosure, environmental non-governmental organizations (ENGOs), by contrast, are significantly more involved in the policy process and information disclosure, often as 'eco-elites'. Overall, this reveals that international and domestic ENGOs retain high-level channels to influence policy design and implementation. Yet, ENGO input is not pursued as a public good valuable for its own sake, but sought strategically as a means to the larger goal of efficient market functioning. This type of 'strategic transparency,' as we call it, suggests that China's environmental governance model - regularly considered to be a key example of authoritarian environmentalism - instead represents an evolving mixture of liberal and illiberal tactics. The case of C-ETS reveals that China's model of authoritarian environmentalism is opening up to include information disclosure and selective participation by ENGOs.Information disclosure, however, still remains limited, with significant differences between provinces and difficulties accessing records via official websites and social media.Industry actors regulated under C-ETS do not have sufficient capacity to engage in information disclosure and often prefer to leave this to third-parties with varying track records.C-ETS information disclosure and ENGO participation represents a type of 'strategic transparency', i.e. transparency as a way to enhance market efficiency.Instead of seeing transparency as a universal objective, policymakers should anticipate strategic transparency when engaging with carbon markets in authoritarian regimes.