The involvement of civil society actors such as NGOs is often presented as one possible remedy to shortcomings in the democratic legitimacy and accountability of institutions of earth system governance. This article uses the case of the United Nations Framework Convention on Climate Change to show how its constituency of environmental and development NGOs has responded to perceived representation and participation deficits in global climate policy-making. It discusses three types of NGO responses, which could potentially help to bring the voices of affected but marginalized communities to the relevant levels of climate policy-making: firstly, NGO proposals designed to remedy representation inequities among governments; secondly, NGO demands for strengthening opportunities for participation by societal stakeholders at all levels of climate policy-making; and finally, representative practices (based on authorization and accountability) reflected in the NGOs’ own decision-making processes and governance structures. With regard to the first two types of responses, the article finds that the NGOs tend to support broadly similar standards of participation and representation in the climate convention. The analysis of the decision-making processes and governance structure of the Climate Action Network, the constituency focal point for the environment and development NGOs in the climate convention, highlights a number of ways through which the network can legitimately claim to represent a wider constituency. At the same time, however, it is important for NGOs not to underestimate the potential costs of high standards of inclusiveness and representativeness.

Keywords: Accountability; Earth system governance; International organizations; Legitimacy; NGOs; Representation; United Nations Framework Convention on Climate Change (UNFCCC); Participation